Pre-immigration planning
The same assets, the same family, the same move — and very different tax outcomes, depending entirely on the order in which the steps are taken.
In short
- Austria taxes residents on worldwide income from the first day of residence — the sequencing of a move decides much of what it costs.
- The entry step-up revalues financial instruments, derivatives and crypto-assets to fair market value at arrival, so pre-move gains on them escape Austrian tax — except on a shareholding of 1% or more in an Austrian company, and on assets returning with someone whose Austrian exit tax was deferred.
- Trust and foundation distributions are the sharpest timing question: before arrival, outside the Austrian net; after arrival, taxed as capital income at 27.5% — one-off payments included, since the rule widened on 1 January 2026.
- Foreign companies must be reviewed for place-of-management and classification risk before the owner sits in Vienna.
- Assets outside the step-up — foreign property, pension entitlements, deferred compensation — need their own pre-move answers.
- A well-run review starts six to twelve months before the move and ends with a documented valuation of everything at entry.
Why the sequence matters
Austrian tax residence is binary. On one side of the line you are a non-resident, taxed in Austria on almost nothing; on the other, a resident taxed on worldwide income — capital income at 27.5%, other income at progressive rates reaching 55%, as mapped on the tax hub. Austria offers no general newcomer regime to soften the transition: as the preferential tax regime page explains, there is no non-dom status, no lump-sum deal, only a narrow relief for scientists, researchers, artists and sportspeople.
What Austria does offer is a system whose outcomes are unusually sensitive to timing. A gain realised the month before residence begins is not Austria's business; the step-up makes the point moot for most portfolio assets, but not for all. A distribution, a dividend, a bonus, a restructuring — each lands on one side of the residence line or the other, and the two sides can be taxed a world apart. The planning discipline is simple to state: identify every asset, structure and expected payment, and decide deliberately which side of the line each belongs on.
Before, not after
The best time to obtain Austrian tax advice is before becoming Austrian tax resident.
The sentence is banal until you price it. Once residence has begun, the step-up values are fixed whether or not they were documented, distributions received are taxable whether or not they were timed, and a foreign company managed from a Vienna desk has already acquired its Austrian problem. None of these can be repaired retroactively — but every one of them can be arranged in advance. Six to twelve months of lead time is usually enough; the relocation timeline shows where the tax workstream sits alongside immigration and property.
What the step-up already solves — and what it does not
The single most important pre-immigration rule is one Austria applies automatically: when you become resident, financial instruments, derivatives and crypto-assets are stepped up to their fair market value at entry. Gains accrued before the move are permanently outside the Austrian net, and there is no need to sell and repurchase a portfolio for Austria's sake. But the step-up has edges, and the planning work concentrates on what lies beyond them.
| Asset or position | At entry | Before the move |
|---|---|---|
| Listed securities, derivatives, crypto-assets | Step-up to fair market value; later gains taxed at 27.5% | Document dated valuations of every account; no forced sales |
| Substantial company shareholdings | Shares stepped up — but not a holding of 1% or more in an Austrian company, which keeps its historic cost; future dividends taxed at 27.5% | Consider distributing retained earnings while non-resident; review management location |
| Foreign real estate | No step-up; where the treaty uses the credit method, or there is no treaty, a later sale is taxed at 30% on the whole historic gain, subject to special rules for long-held property — many treaties exempt the gain instead | Check the treaty's method article for each property before weighing realisation or restructuring pre-move |
| Trust and foundation interests | No step-up; distributions and attribution rules apply from day one | Classify the structure; time distributions before arrival where sensible |
| Pensions and deferred compensation | No step-up; receipts can be taxed at progressive rates | Examine lump-sum timing and the applicable treaty article |
| Stock options, carried interest, bonuses | No step-up; payments after arrival can fall partly into the Austrian net | Map vesting and payment dates against the residence date |
The flat rates, the bank-withholding convenience and the treatment of investment funds that apply once you are resident are set out on the investment income and capital gains page — including the reporting-fund question that decides whether a foreign fund portfolio is taxed sensibly or penally in Austria, itself a classic pre-move review item.
Trusts and foundations: the timing question
No part of a pre-immigration review carries more value per decision than the family's trusts and foundations. Austria, a civil-law country, fits common-law trusts into its system by classifying them as transparent or non-transparent, with consequences described on the foreign trusts and foundations page. For a beneficiary about to become Austrian resident, the headline is timing: a distribution received while still non-resident is simply outside the Austrian net; after arrival, distributions from a non-transparent trust or other foundation-like structure are capital income taxed at 27.5%, whether one-off or recurring — the exemption a single lump-sum payment once enjoyed disappeared on 1 January 2026. A transparent trust's income, meanwhile, is attributed to an Austrian-resident beneficiary as it arises, distributions or not.
The review therefore asks, structure by structure: how would Austria classify it — who really controls the management? Should a planned distribution be brought forward? Should the structure be amended, collapsed, or replaced with an Austrian private foundation, whose regime is purpose-built and treaty-resident? Endowing assets into structures also has a price of its own — 3.5% into an Austrian foundation, but 25% into a non-transparent trust — though the charge only bites where the person endowing, or the structure itself, already has an Austrian residence, seat or place of management, so an endowment completed before arrival falls outside it. One more decision cheaper to take deliberately than by default.
Companies: decide where management will sit
A founder or owner who moves personally while the companies stay abroad has not answered the tax question — merely postponed it to the first Monday morning in Vienna. A foreign company whose key decisions are taken from Austria can become Austrian tax resident, taxed at 23% on worldwide profits, or acquire an Austrian permanent establishment; a low-taxed passive vehicle under an Austrian holding company walks into the CFC rules. The foreign income and companies page sets out the tests, and the relocating your company page compares the deliberate alternatives: genuine foreign management, an Austrian subsidiary or holding company, or a formal migration.
The pre-move task is governance, not paperwork: appoint and empower directors abroad, fix where boards actually meet, and decide before arrival which entities should distribute their retained profits to a still-non-resident owner — a dividend that costs 27.5% less on one side of the line than the other.
Compensation, pensions and insurance wrappers
Income that is earned before the move but paid after it — vesting stock options, carried interest, deferred bonuses — is the untidiest category. Austria will generally tax what is received while resident, treaties allocate entitlement by reference to where and when the income was earned, and the outcome varies plan by plan. Mapping every vesting and payment date against the intended residence date, and examining what can properly be brought forward, routinely repays the effort many times over.
Pensions deserve the same scrutiny: lump sums that would be tax-favoured at home can be taxed at progressive Austrian rates, and the applicable treaty's pension article decides which state taxes what. Life-insurance wrappers, popular in several departure countries, are respected or looked through by Austria depending on their terms — policyholder influence over the investments is the danger sign — so each policy should be reviewed, and if necessary adjusted, before arrival. US-linked families face an additional layer across all of this, summarised on the US citizens page.
The departure country has a say
Pre-immigration planning is a two-country exercise. Many departure countries levy their own exit taxes on unrealised gains or substantial shareholdings when residence ends, some claw back reliefs on early departure, and several keep taxing former residents for a period after they leave. None of this is Austria's doing, but all of it belongs in the same calendar: the departure-country exit value and the Austrian entry value are fixed at the same moment, and aligned, well-documented valuations prevent both gaps and overlaps between the two systems. We coordinate with advisers in the country of departure as a matter of course — the sequencing only works if both ends move together.
Document the move
The final workstream is evidence. Fix the residence-commencement date deliberately — when a dwelling becomes available and when presence begins are legal facts, explained on the tax residence page, and ambiguity serves no one. As of that date, obtain dated statements and valuations for every securities account, crypto wallet and company interest: these anchor the step-up and every later Austrian computation. Preserve acquisition-cost records from the old life, including for crypto legacy holdings where the acquisition date itself decides taxability, as described on the crypto-assets page. And where a home in the departure country is kept, start the day lists that the residence rules will one day ask for. Then the move itself can proceed — on the practical schedule set out in the relocation timeline.
Questions on this page
When should tax planning for a move to Austria begin?
Ideally six to twelve months before the move. Restructuring companies, reviewing trusts and foundations, and timing distributions all take months to execute properly, and every option is wider while you are still non-resident.
Do I need to sell my investments before moving to Austria?
Usually not. Austria grants a step-up to fair market value on financial instruments, derivatives and crypto-assets when you become resident, so gains accrued before arrival are not taxed here. Assets outside the step-up, such as foreign real estate, deserve a closer look.
Why should trust or foundation distributions be considered before becoming Austrian resident?
A distribution received before residence begins is outside the Austrian tax net. Once you are resident, distributions from a foreign foundation or foundation-like structure — a non-transparent trust included — are capital income taxed at 27.5%, one-off and recurring alike: the escape route of a single lump-sum payment closed on 1 January 2026.
Can I still plan after I have already moved to Austria?
Some options remain — structures can be reorganised and future income planned — but the most valuable levers, such as the timing of distributions, pre-arrival realisations and the step-up documentation, only work before residence begins.
What should I document on the day I become Austrian tax resident?
Dated valuations of every securities and crypto account for the step-up, records of acquisition costs and dates, and evidence fixing the residence-commencement date itself. These documents anchor every later Austrian tax computation.
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.
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