GmbH shareholder account in Austria 2027: €50,000 limit, 27.5 % tax

From 2027, a shareholder in Austria must settle what they owe on the GmbH's Verrechnungskonto (shareholder current account) by the balance-sheet date: anything still open above €50,000 counts as a dividend and costs 27.5 % KESt (capital gains tax) (§ 8 Abs. 2a KStG 1988). For a GmbH with a calendar financial year, the first test date is 31 December 2027; with a different financial year it can come as early as the start of 2027.

Law as of 9 November 2026

The rule applies to every GmbH and FlexCo with a shareholder who is an individual, whatever the size of the stake. It is enacted and published in the Federal Law Gazette (Budgetbegleitgesetz 2027-2028, BGBl. I Nr. 62/2026). So you have a little over a year to bring a high balance down or turn it into a proper loan agreement.

The new rule at a glance

What the shareholder account is and why it now costs money

The GmbH books everything that passes between it and its shareholder on the Verrechnungskonto: private withdrawals, private bills the company pays, contributions, or director's pay not yet paid out. If you, as shareholder and managing director, take money out for private use, the GmbH has a claim against you. The account is negative, and you owe the company money.

Until now, the tax office treated such a balance as a hidden distribution only case by case, for example when it was clear you could not or would not repay (§ 8 Abs. 2 KStG 1988). According to the explanatory notes to the government bill, these accounts often grew for years without anyone repaying. So the legislator draws a fixed line: at the balance-sheet date the account must be settled, or the part above €50,000 is taxed like a dividend.

Below the threshold there is no automatic distribution. The general rules on hidden distributions in § 8 Abs. 2 KStG 1988 still stand.

When the rule starts

The rule applies first to financial years ending in calendar year 2027 (§ 26c Z 101 KStG 1988). Your first test date:

A non-calendar financial year is the real trap: if yours ends on 31 January 2027, you have less than three months from early November 2026. The rule also covers receivables that have sat on the account for years. Old balances are not grandfathered.

When the tax is due

If you do not settle the account by the test date, the amount above €50,000 counts as openly distributed and received on the day after the resolution to draw up the annual accounts (§ 222 Abs. 1 UGB, the Austrian Commercial Code), at the latest after five months. Management has to draw up the annual accounts within the first five months of the new financial year anyway.

The GmbH must withhold the KESt and pay it to the tax office within one week of that date (§ 96 Abs. 1 Z 1 EStG 1988), even though no money was paid out to you. The rate is the one for dividends, 27.5 % (§ 27a Abs. 1 Z 2 EStG 1988).

How to settle the shareholder account

Check the balance in the autumn before the test date, not when the accounts are drawn up. Bookings and reconciliations often happen only during year-end closing, and by then the date has passed.

1. Get the balance. Ask for the account balance, for example as of 30 September, and add the withdrawals expected until year-end.
2. Repay. Transfer the amount above €50,000 from your private money to the GmbH before the test date. This costs no tax.
3. Set it off against claims. If you have claims against the GmbH, such as director's pay not yet paid out or a dividend already resolved, they can settle the account. You pay tax on them as usual: pay at the income tax rates, a dividend at 27.5 % KESt.
4. Turn it into a loan. The law also accepts an arm's-length loan from the GmbH to you. It must be in place before the test date: in writing, with ongoing interest and a duty to repay. According to the parliamentary committee report, an interest rate that is slightly too low does not trigger the distribution on its own; the overall picture decides.
5. Keep the evidence. Keep the loan agreement, the proof of payment and the account statement at the test date. In a dispute you have to prove the settlement.

Worked example

Anna is the sole shareholder and managing director of a GmbH with a calendar financial year. Over the years she has taken out more privately than her pay. On 31 December 2027 her shareholder account is €80,000 negative.

Management resolves to draw up the annual accounts on 15 April 2028. The €30,000 counts as received on 16 April 2028, and the GmbH must pay the €8,250 KESt by 23 April 2028. Without a resolution, the date would be five months after the test date at the latest, so the end of May 2028.

If Anna instead pays €30,000 into the company account by 31 December 2027, the balance stays at €50,000 and no KESt arises. If she does not want to pay, she can turn the whole €80,000 into a written, interest-bearing loan with a repayment plan before the test date.

Where early guides and German rules differ

• The June 2026 draft was different. In the government bill, the €50,000 threshold applied only to shareholders with a stake of at least 10 %, and the distribution was to arise on the day after the balance-sheet date. The budget committee changed both: the threshold now applies to every shareholder, and the date follows the resolution to draw up the accounts. Guides from summer 2026 are often out of date here.
• It is an Austrian rule. Germany has no fixed €50,000 limit for the shareholder account. If an AI answer or a German site describes such a rule "in Germany", it is describing the Austrian one.
• There is no UG. In Austria the rule concerns the GmbH and the FlexCo. The minimum corporate tax of €500 a year applies regardless.

As a shareholder-director with more than 25 %, your pay is taxed as self-employment income. That makes you eligible for the Gewinnfreibetrag (profit allowance); the free profit allowance calculator shows how much it is worth.

Norman in Austria

Norman is an AI bookkeeping app for the self-employed and companies. In Germany and Poland it captures receipts by photo, matches bank transactions, writes invoices and prepares tax returns; for Austria, Norman is in preparation. Until then you will find free guides to Austrian law here, for example on the profit allowance, and everything about Norman's launch in Austria.

Frequently asked questions

When does the €50,000 shareholder account limit start in Austria?

For financial years ending in calendar year 2027. For a GmbH with a calendar financial year, the first test date is 31 December 2027; with a different financial year, an earlier date in 2027.

Do I have to repay the whole shareholder account?

No, for tax purposes only the part above €50,000 matters. If more is open at the test date, only the excess counts as a distribution and is taxed at 27.5 % KESt.

Does the limit apply to a small stake too?

Yes. In the enacted law, the €50,000 limit applies to every shareholder who is an individual, whatever the size of the stake. The 10 % threshold was only in the draft.

How do I turn the shareholder account into a loan?

With a written loan agreement before the balance-sheet date that provides for ongoing interest and repayment, on terms unrelated parties would agree. The interest must then actually be paid.

Who pays the KESt on the deemed distribution?

The GmbH must withhold the 27.5 % KESt and pay it to the tax office within one week. The relevant date is the day after the resolution to draw up the annual accounts, at the latest after five months.