The protocol updates the 1974 treaty with anti-abuse provisions, a 0% withholding tax on qualifying dividends, revised permanent establishment rules, and expanded tax information exchange and collection assistance.
Austria’s Federal Council (Bundesrat) approved the protocol to the 1974 income and capital tax treaty with Switzerland on 22 October 2026, following the National Council’s approval on 14 October 2026.
Signed on 30 July 2026, the protocol is the sixth amendment to the treaty. The protocol updates the Austria–Switzerland tax treaty to align with international minimum standards and strengthen measures against tax abuse.
Key changes include a Principal Purpose Test to deny treaty benefits in abusive cases, a 0% withholding tax on qualifying dividends, updated permanent establishment rules, mutual assistance in tax collection, and expanded information exchange that cannot be refused on bank secrecy grounds.
It will enter into force on the first day of the second month after the exchange of ratification instruments and apply from 1 January of the following year.
Earlier, the Swiss State Secretariat for International Finance announced that Austria and Switzerland signed a protocol amending their 1974 income and capital tax treaty on 30 July 2026.
