Case studies
Six composite scenarios show how the moving parts of a relocation interact. None is a real client — and every rule they turn on is linked.
In short
- Six composite scenarios show how a relocation's moving parts interact: the residence route, the tax-residence date, companies, portfolios, trusts, foundations and property.
- None is a real client matter — the facts and outcomes are invented to illustrate the rules, and only that.
- Each scenario links the pages that explain the rules it turns on, so any thread can be followed into the detail.
Illustrative composites. The families and outcomes described on this page are invented for illustration. They are not real clients, the figures are not promises of any result, and no scenario is advice for an actual situation — every real case turns on its own facts, timing and treaty positions.
How to read the scenarios
The rules of a relocation are described one page at a time across this site; real moves arrive as combinations. The scenarios below are drawn as typical constellations — an entrepreneur under two tax systems at once, a family arriving after a liquidity event, an executive between two treaty states, a part-year base, companies left behind, a foundation awaiting classification. Read them alongside the first 10 questions, and follow the links into the detail pages. The table lists the rules and 2026 figures the six stories keep returning to.
| Rule or figure | Position (2026) | Scenarios | Explained at |
|---|---|---|---|
| Flat tax on capital income | 27.5% (bank interest 25%) | 1, 2, 6 | Investment income and capital gains |
| Step-up to market value on arrival | Gains accrued before residence stay untaxed in Austria | 1, 2 | Pre-immigration planning |
| Company managed from Austria | Corporate income tax 23%; permanent-establishment risk | 5 | Foreign income and companies |
| Secondary-residence rule | At most 70 days' use a year, day list kept | 4 | Tax residence |
| Distributions from an opaque trust | 27.5% where the structure is comparable to a private-law foundation, one-off or recurring; otherwise up to 55% on recurring payments | 6 | Foreign trusts and foundations |
| Foundation transfer tax | 3.5% to an Austrian private foundation; 25% to a non-transparent trust | 6 | Austrian private foundation |
| Red-White-Red Card, other key workers | Salary at least EUR 3,465 per month (2026), labour market test, 55 of 90 points | 1 | Red-White-Red Card |
| Independent-means permit | Annual quota; applications in early January; German A1 | 2, 4 | Financially independent persons |
| Social-security contribution cap | EUR 97,020 per year (2026) | 3 | Social security |
| All-in property purchase costs | ≈9–11% of the price (indicative) | 2, 4 | Purchase process and costs |
1. The US tech entrepreneur from California
The situation. A software entrepreneur in California has sold part of his company and holds the remainder as listed stock, alongside a sizeable crypto portfolio. He and his family want to move to Vienna, from where he will lead the firm's European business.
The issues. US citizens remain inside the US worldwide tax net wherever they live, so two systems apply at once. Austria grants a step-up to market value on arrival; the United States does not, so the two tax bases diverge from day one. A portfolio rebuilt with European funds risks PFIC treatment in US hands, while crypto gains fall under Austria's flat 27.5% once he is resident. His employment provides the immigration route: the Red-White-Red Card for other key workers — a salary of at least EUR 3,465 per month (2026), a labour market test and at least 55 of 90 points on the key-worker criteria, a decision due within eight weeks of a complete application, and no German requirement, since German earns points rather than being a condition.
The planning. US and Austrian advisers are coordinated before the move; stock and crypto are valued and documented at the moving date; the future portfolio is screened for PFIC exposure and Austrian fund-reporting status; any disposals are sequenced against both systems' calendars.
The outcome (illustrative). Residence through the key-worker card, a portfolio both systems can live with, and a filing calendar covering Vienna and the IRS alike — the trade-offs described on the US citizens page made deliberately rather than discovered.
2. The UK family after a business sale
The situation. A British couple has sold their trading company. The proceeds sit in cash and a managed portfolio, part of the price is deferred as an earn-out, and their two children are of school age. Vienna is chosen for its schools, safety and quality of life.
The issues. UK nationals are now third-country nationals, so a residence title is needed; the natural fit is the residence permit for financially independent persons — quota-bound, applied for in early January, with basic German (A1), full health cover and sufficient fixed income required. The earn-out must be reviewed against the date Austrian residence begins, since income that trails the sale may land in a different system from the sale itself. The portfolio benefits from the entry step-up if values are documented. And under the EU Succession Regulation, Austrian succession law — with its compulsory portions — would govern their estates by default once they are habitually resident here.
The planning. The application is filed in the January quota window; the earn-out is restructured before the residence date; market values are documented; school applications go in early; the wills are redrawn with an express choice of the law of their nationality.
The outcome (illustrative). Permits within the annual quota, a stepped-up portfolio, school places secured, and wills that choose their own law instead of inheriting Austria's defaults.
3. The Swiss executive employed in Vienna
The situation. A Swiss national is appointed to run a group's Central and Eastern European division from Vienna. She starts in the spring; her family follows at the end of the school year.
The issues. As a Swiss citizen she needs no residence permit — registration is a formality. The harder question is tax: during the transition she has a home in both countries, so the Austria–Switzerland treaty tie-breaker decides where she is resident — permanent home first, then centre of vital interests, where family ties weigh heavily. Her Austrian employment income is withheld through payroll; the 13th and 14th salaries are taxed at the fixed rates for other payments — nil on the first EUR 620, 6% on the next EUR 24,380, then 27% and 35.75% — so at her level only the first slice enjoys the 6% rate. Social-security contributions are capped at a base of EUR 97,020 per year (2026), and incentive awards earned before arrival need separate review.
The planning. The family's move is sequenced deliberately so that the centre of vital interests shifts once, not gradually; the option plan is reviewed for pre-arrival vesting; registrations and payroll are set up within the deadlines.
The outcome (illustrative). A clean single-residence position under the treaty once the family arrives, compensation structured around the contribution cap, and no surprises in the first tax return — the mechanics are on the tax residence page.
4. The Middle Eastern family establishing a Vienna base
The situation. A family from the Gulf wants a Vienna apartment as a European base — used for a few months each year, with a full relocation possible later.
The issues. An apartment kept and available can itself create a domicile, and with it worldwide taxation. The secondary-residence rule protects them only if the centre of vital interests has been abroad for more than five years, the flat is used at most 70 days a year, and a day list is actually kept — by both spouses. As non-EEA buyers they need land-transfer approval in Vienna, or a structure that removes the requirement. Their stays are limited to 90 days in any 180-day period, visa-free for Emirati nationals but on a Schengen visa for nationals of Saudi Arabia, Qatar, Kuwait, Bahrain and Oman, and buying the apartment confers no residence right — Austria has no golden visa. Austrian banks will expect thorough source-of-funds documentation.
The planning. Day lists are kept from the first visit; the purchase is structured and approved properly; the banking file — sale agreements, tax returns, audited accounts — is prepared before the account opening; the later upgrade to an independent-means permit is mapped but not yet triggered.
The outcome (illustrative). A Vienna base without unintended tax residence, documented compliance with the 70-day rule, and a prepared path to full relocation whenever the family chooses it.
5. The founder who moves while the companies stay abroad
The situation. A founder moves to Vienna with her family. Her two operating companies remain abroad, each with a local team and local directors, and she intends to stay closely involved.
The issues. A company is Austrian tax resident where its legal seat or its place of management lies — routine decision-taking from a Vienna desk can pull a foreign company into 23% Austrian corporate income tax, or create a permanent establishment. The CFC rules attribute the passive income of a low-taxed foreign subsidiary — one bearing an effective foreign tax burden below 15% — only to a controlling Austrian corporate body, a holding company or an Austrian private foundation alike, so they bite on a structure rather than on shares she holds herself. Her future dividends arrive at the flat 27.5%, and an Austrian holding company could access the participation exemptions for the group's next stage.
The planning. Real management authority stays abroad and is seen to stay abroad: board calendars, minutes and travel document where decisions are taken, and her own Austrian role is defined in writing. The holding-company question is decided before the move as part of pre-immigration planning, not repaired afterwards.
The outcome (illustrative). The companies keep their foreign tax residence, the founder is taxed in Austria on what she draws, and the governance file proves the arrangement — the options are compared under relocating your company.
6. The family with a Liechtenstein foundation
The situation. Parents moving to Vienna are beneficiaries of a Liechtenstein foundation that has held the family's investment portfolio for a generation.
The issues. Everything turns on classification. A foundation comparable to an Austrian private foundation is generally taxed under the Austrian foundation regime, with distributions at the flat 27.5%. Since 1 January 2026 the comparability test is wider, so many more trusts fall inside it and their distributions bear the same flat 27.5%, one-off or recurring alike. A structure that stays outside that class faces harsher arithmetic: recurring distributions to Austrian-resident beneficiaries at progressive rates of up to 55%. Either way, endowments made once the family is resident attract 25% foundation transfer tax — against 3.5% for an Austrian private foundation. A transparent structure is disregarded altogether, its income attributed to the beneficiaries as it arises.
The planning. The foundation is classified before the move; governance is adjusted where the likely classification is unwanted; distributions are timed — a distribution received before Austrian residence begins falls outside Austrian tax altogether, one received after may not. The review sits inside the wider pre-immigration sequence.
The outcome (illustrative). The structure's Austrian treatment is known and chosen rather than discovered, and the distribution policy is fixed before day one — the tests are explained under foreign trusts and foundations.
Questions on this page
Are these case studies real client matters?
No. Each scenario is an illustrative composite, built to show how the rules interact. The families, facts and outcomes are invented and describe no real person.
Can I read my own tax position off a scenario?
No. The scenarios show which questions arise and in which order. The numbers in a real case depend on individual facts, treaty positions and timing, and need individual advice.
What if my situation combines several scenarios?
That is the normal case. Most relocations mix elements — a company, a portfolio, a property, a structure — and the planning sequence is set for the combination, not for each part alone.
Considering a move to Austria?
Tell us where you stand — the country you are leaving, the shape of your family and your assets, and when you plan to move. We advise on the legal and tax consequences of relocating to Austria and coordinate with advisers in the country of departure.
Message sent
Thank you for your enquiry. We will review your message and respond shortly.