New Rules for Filings via FinanzOnline
Use of the Specific Function Instead of “Other Applications and Requests”
The newly published FinanzOnline Ordinance 2027 contains an exhaustive list of applications and submissions for which a separate, dedicated function is available in FinanzOnline. These include, among others, tax returns, appeals, requests for referral to the administrative court, applications for extensions of filing deadlines, and numerous other submissions.
As a result of the FinanzOnline Ordinance 2027, as of 1 January 2027, the designated function must be used for all submissions listed in the Ordinance. This applies regardless of whether the relevant tax legislation requires an electronic filing or whether the submission is made electronically on a voluntary basis.
Other Applications and Requests
The general “Other Applications and Requests” function is no longer intended to serve as an alternative filing channel. Only submissions for which no dedicated FinanzOnline function is available, as well as explanations or attachments that must be submitted separately for technical reasons, may continue to be transmitted to the tax authorities via the “Other Applications and Requests” function.
The Ordinance also clarifies that submissions made through this general function may only be filed with the Austrian Tax Office (Finanzamt Österreich) or the Large Taxpayers Tax Office (Finanzamt für Großbetriebe). They may not be submitted to other authorities, such as the Office for Combating Tax Fraud (Amt für Betrugsbekämpfung, ABB) or the Customs Office (Zollamt). Such submissions will not be processed by the tax authorities.
Penalty for Vexatious Conduct
If a matter that is subject to a statutory obligation for electronic submission and for which a dedicated FinanzOnline function is available is not submitted through the prescribed function, the tax authority may, in the event of repeated non-compliance, impose a penalty for vexatious conduct of up to EUR 700.
However, such a penalty may only be imposed if the taxpayer has previously been informed in writing of the obligation to use the designated electronic submission channel and has been advised of the potential penalty in the event of repeated non-compliance.
Unreasonableness of Electronic Submission
As a general rule, submissions may be made either by post or electronically to the tax authorities. However, certain filings are required by law to be submitted electronically, such as tax returns or the registration of cash register systems.
Where tax legislation provides for mandatory electronic submission, an exception is only possible if electronic filing cannot reasonably be expected from the taxpayer due to a lack of technical prerequisites. Such unreasonableness exists, for example, where the taxpayer does not have access to the internet or where their access to FinanzOnline has been suspended.
Given today's circumstances, electronic submission can therefore generally be expected and regarded as reasonable in the vast majority of cases.