Summary
- The BFG (1 April 2026, RV/2100573/2024) denies input VAT deduction from the acquisition and conversion costs of a building designated as a “training and event centre” that actually serves predominantly private leisure purposes of employees and managing directors.
- The actual use and documented business purpose are decisive — the mere designation of the building or occasional stays of employees are not sufficient.
- For the recognition of training or team-building measures, plausible concepts, concrete measures, and a clearly documented business motivation are required.
Article
In its decision of 1 April 2026 (RV/2100573/2024), the BFG denied input VAT deduction for a real estate investment in Austria. A German-based group company (construction sector) had purchased a former inn/hotel in 2019 for around €1.23 million and, in 2019/2020, converted it for a further approximately €3.125 million into a “training and event centre” of the corporate group — with 21 sleeping units and living areas for the managing directors.
Based on findings of the tax audit, the property actually served predominantly the private leisure of employees and their families as well as of the managing directors. No specific training or team-building concepts were demonstrated; the mere designation as a “training centre” was insufficient for the BFG. It therefore denied the input VAT deduction under § 12(1) Z 1 lit. a of the Austrian VAT Act, since the expenses were not used for the business but were attributable to the area of private lifestyle or a voluntary social contribution to employees.
The BFG makes it clear: the recognition of business training or team-building measures requires documented concepts, concrete training plans, and a clearly traceable business purpose. Mere stays or the labelling of the building are not sufficient if the evidence base predominantly points to private leisure purposes.
Practical relevance: Corporates that build or rent training, conference, or “off-site” properties should ensure from the outset a substantial business use concept (training calendar, booking system, occupancy statistics, documented team-building programmes), minimise private use, or charge it at arm’s length.
External links
- https://findok.bmf.gv.at/
- https://www.ris.bka.gv.at/NormDokument.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10004873&Paragraf=12
- https://www.bmf.gv.at/
- https://www.vatupdate.com/category/europe/austria/
