Austria’s upcoming Abgabenänderungsgesetz 2025 includes a revolutionary provision allowing tax-neutral transfers of foreign securities portfolios to domestic brokers starting July 1, 2026. Investors can repatriate assets without triggering immediate capital gains tax, provided they disclose original acquisition costs to the Finanzamt within one month. This reform, buried within tobacco tax legislation, solves a decades-old pain point for expats and international investors but introduces strict compliance requirements that could invalidate the tax benefit if missed.
The Bureaucratic Miracle Hidden in Tobacco Legislation
On December 2, 2025, Austria’s Finanzausschuss approved a sprawling 17-measure tax package that will amend over 20 federal laws. While headlines focused on the controversial tobacco tax increases and the death of fax communication with authorities by 2027, a quiet revolution for investors slipped through almost unnoticed. The provision titled “Erleichterung der Rückführung von Wertpapieren” (Facilitation of Securities Repatriation) fundamentally changes how Austrians can bring foreign-held assets home.
For decades, moving a portfolio from, say, Interactive Brokers or a Swiss bank to a local Austrian broker meant treating the transfer as a taxable sale. The difference between your original purchase price and market value would trigger KESt (Kapitalertragsteuer) immediately, even if you never touched the money. This forced many Austrian residents with foreign accounts into a devil’s choice: keep assets abroad for tax efficiency but face compliance headaches, or repatriate and lose a chunk to taxes.
The new rules, set to take effect July 1, 2026, declare such transfers tax-neutral events. You can now move your entire foreign portfolio to Austria without triggering a tax bill, preserving the original acquisition cost basis for future taxation.
The One-Month Tightrope Walk
Here’s where Austrian efficiency meets bureaucratic obsession. The tax-free treatment hinges entirely on a single, non-negotiable deadline: within one month of the transfer, you must report the original acquisition costs to both your new Austrian depot provider and the Finanzamt. Miss this window, and the transfer automatically becomes a taxable event at market value.
This isn’t a casual “get around to it” requirement. The law explicitly demands proactive disclosure. Many investors misunderstand this as a passive obligation, assuming their new broker handles it automatically. They don’t. You, the account holder, bear sole responsibility for providing accurate historical cost data.
The implications are severe. Imagine transferring a portfolio worth €500,000 where your original investment was €200,000. If you miss the one-month deadline, the Finanzamt treats the €300,000 gain as realized income in that tax year. At the 27.5% KESt rate, that’s an €82,500 tax bill for moving your own money from A to B.
When Acquisition Costs Aren’t What You Think
The rule contains a particularly Austrian twist for ETF and fund investors. The reported acquisition cost must be the “steuerliche Anschaffungskosten” (tax-relevant acquisition cost), not necessarily what you actually paid. For foreign funds that weren’t previously subject to Austrian tax law, this means calculating a fictional entry price according to Austrian regulations.
This distinction trips up even experienced investors. The tax-relevant cost basis often differs from your brokerage statement due to:
– Currency conversion rules at purchase date
– Adjustments for foreign tax credits
– Treatment of accumulated distributions before Austrian residence
Tax advisors report that many foreign brokers don’t track this Austrian-specific data, leaving investors to reconstruct it from historical exchange rates and fund documentation. The Finanzamt accepts reasonable estimates, but documentation is critical, receipts, annual statements, and screenshots of historical prices.
The Kinderdepot Loophole That Changes Estate Planning
Perhaps the most strategically interesting aspect involves transferring assets to children’s accounts. Austrian law already allows KESt-free gifting of securities to minors through a Kinderdepot, but previously this only worked for domestic transfers. The 2026 reform extends this to foreign portfolios.
This creates powerful succession planning opportunities. Parents with substantial foreign investments can transfer appreciating assets to their children tax-free during their lifetime, letting future growth accumulate under the child’s lower tax bracket. The same one-month disclosure rule applies, but the potential tax savings across generations dwarf the administrative burden.
Critically, this works only for direct transfers to a properly structured Kinderdepot. Transferring to your own account first, then gifting, would trigger two tax events. The direct foreign-to-child route remains tax-neutral.
Digitalization and the Death of Fax
The portfolio transfer reform sits within a broader modernization push. The same law mandates that by 2027, Austrian authorities will no longer accept fax submissions, a change that somehow feels both revolutionary and embarrassingly overdue. The Grunderwerbsteuer (real estate transfer tax) goes fully digital in April 2026, with insurance tax following in 2027.
This digital shift matters for investors. The acquisition cost disclosure will presumably happen through FinanzOnline, Austria’s tax portal. Yet the law’s text doesn’t specify the exact mechanism, creating uncertainty. Will a simple online form suffice? Must you file a formal request for a “Freistellungsbescheid” (exemption notice)?
Tax professionals advise preparing documentation in advance and filing through your Steuerberater, at least for the first year. The Finanzamt’s IT systems have a history of struggling with novel processes, and you don’t want your tax-free transfer stuck in digital purgatory.
Preparing for the July 1, 2026 Launch
If you’re holding foreign assets, start preparation now. The one-month deadline leaves no room for digging through old paperwork.
Immediate action items:
1. Document everything: Compile all trade confirmations, account statements, and dividend reinvestment records. Screenshot current holdings with ISIN numbers and market values.
2. Calculate tax-relevant costs: For foreign ETFs/funds, work with a Steuerberater to determine Austrian-compliant acquisition costs. Don’t wait until mid-2026 when tax offices are overwhelmed.
3. Choose your Austrian broker wisely: Not all brokers are prepared for this process. Ask specifically about their support for the new disclosure requirements. Major banks like Erste Bank and Raiffeisen have dedicated international client desks, fintech brokers may lag behind.
4. Time strategically: If you’re planning a transfer anyway, waiting until July 1, 2026 makes sense. But if you need liquidity before then, remember the old rules still apply, consider realizing gains in low-income years.
The Political Context: Why This Passed
The unusual breadth of support for the Abgabenänderungsgesetz 2025, backing from ÖVP, Grüne, SPÖ, and NEOS, stems from its piecemeal nature. Each party found something to champion: the Greens loved the tobacco restrictions, the SPÖ praised the inflation adjustments, NEOS celebrated digitalization, and the ÖVP secured revenue increases.
Only the FPÖ hesitated, holding out for final negotiations. This consensus suggests the portfolio transfer provision, while significant, flew under the radar of political controversy. It’s a technocratic fix to a practical problem that had been raised by banking associations and expat advocacy groups for years.
The projected revenue increase of €446-465 million comes almost entirely from tobacco, not from closing investor loopholes. This allowed the government to offer a genuine concession to international investors without budgetary cost.
The Austrian Way: Generous but Complicated
This reform exemplifies Austria’s Janus-faced approach to financial regulation: genuinely helpful policy wrapped in potentially punitive bureaucracy. The tax-free transfer is real and valuable, but the one-month disclosure rule transforms it from a right into a privilege for the organized.
The Finanzamt won’t send reminders. Your broker won’t prompt you. The tax administration assumes you’ve read the Bundesgesetzblatt and set calendar alerts. This is the same system that still required fax submissions in 2025, efficient in theory, unforgiving in practice.
For Austrian expats returning after years abroad, this reform removes a major financial friction point. For foreign residents building lives in Vienna, Graz, or Innsbruck, it simplifies compliance without forcing tax inefficiency. But for everyone, it demands the same meticulous attention to Austrian procedural detail that makes opening a bank account feel like applying for security clearance.
The days of keeping foreign portfolios hidden from the Finanzamt are over anyway, with automatic exchange of information agreements now standard. Better to bring assets home on your own terms, just don’t forget to file that form within 30 days.
Bottom line: Mark July 1, 2026, on your calendar. Then mark the date 30 days later as your personal tax apocalypse if you haven’t disclosed your acquisition costs. Austria just made portfolio repatriation tax-free, but in typical Austrian fashion, they’ll tax you heavily if you don’t appreciate their generosity quickly enough.
