Abstract (eng)
This master thesis is intended to explain the reasons and the design of the deduc-tion restriction for certain interest and royalty payments according to §12 Abs 1 Z 10 KStG. The individual requirements of the deduction restriction will be examined in detail and their effects will be illustrated by examples. In addition, the EU compliance of the deduction re-striction will be discussed. One focus of this master thesis is the rash implementation of a tar-geted deduction restriction in relation to general abuse provisions (including the revised ver-sion of §22 BAO) and general deduction restrictions (interest deduction limitation based on the OECD BEPS report and the Anti Tax Avoidance Directive ATAD).