Optimising tax in a GmbH: four legal strategies
From the split between salary and dividend to Forschungsprämie and group taxation — four mechanisms that work within the law.
The word "optimisation" sounds suspicious in the Austrian context — and unfairly so. The law itself offers several mechanisms for reducing the tax burden; the only question is whether you use them or pay the full rate out of habit. Four tools we apply most frequently for GmbH.
First: the ratio between salary and dividend
A GmbH's profit is subject to corporate tax (KöSt) at 23%, and a dividend paid to the owner is taxed at an additional 27.5% capital gains tax. A director's salary, by contrast, reduces the company's profit but carries social insurance contributions and progressive income tax. The optimum almost never lies at either extreme: it lies in a ratio calculated on the specific figures of the year.
A practical rule: we first use the salary to cover the need for social protection and documented income (mortgage, visa matters), and treat the remainder as a dividend. We recalculate every year — the progression thresholds and your personal situation change faster than tax law.
Second: Forschungsprämie — 14% in real money
The research premium returns 14% of R&D expenditure — not as a reduction of the tax base, but as a payment to the tax account. This applies not only to laboratories: development of a software product, substantial improvement of a process, or a prototype of a new service often qualify. The condition is an expert opinion from FFG and tidy documentation of hours.
Forschungsprämie is a rare case where the state pays a business for what it was already doing. Companies lose it not through rejection, but through timesheets that were never collected.
Third: Gruppenbesteuerung
If you have more than one company, the group arrangement allows the loss of one to be offset against the profit of another. The conditions: a shareholding of more than 50%, an application to the Finanzamt, and a commitment to maintain the group for a minimum of three years. The most common scenario is a young company with losses alongside a mature one: instead of two separate results, you are taxed on a single combined figure.
Fourth: investment incentives that apply only until the end of 2026
The Investitionsfreibetrag has been temporarily increased from 10% to 20%, and for environmental investments from 15% to 22%. The maximum base is one million euros per year. This is an additional deduction in the accounts that does not reduce the depreciation base: you write off the equipment as normal and receive the incentive on top. The condition is new assets with a useful life of at least four years and four years of retention.
None of these tools is a scheme: all four are set out in law and reviewed by the Finanzamt without drama. The difference between a company that pays the full rate and one that pays a reasonable rate is usually not a matter of boldness — but of the fact that the second one did the calculations in March, not in December.
We handle filings for FOP and small companies — from a first EAR to Basispauschalierung. This rubric breaks down what the Finanzamt checks most often.