The category of CFC income referred to as income from invoicing companies in the sense of Sec 10a para 2 no 6 Austrian CITA raises a variety of complex interpretation issues, but has received little scholarly attention so far. Thus, Daniel W. Blum and Raphael Holzinger aim at shedding light on both the rule’s constitutive elements as well as its interplay with another already existing concept of corporate taxation that pursues a similar purpose, i.e. transfer pricing. In doing so, the authors pay particular attention to the disputed issue whether so-called “limited or low risk distributors" are covered by the term “invoicing company" and thus can lead to CFC income inclusion pursuant to Sec 10a CITA.
