Austria / Switzerland · International tax development
Austria completes parliamentary approval of Switzerland tax-treaty protocol
On 22 October 2026, Austria’s Federal Council approved the Austria–Switzerland tax-treaty protocol, following National Council approval on 14 October. Parliamentary approval does not establish entry into force or permit immediate use of the revised reliefs.
- Official document:
- Federal Council approval 220/BNR; protocol signed 30 July 2026 amending the Austria–Switzerland income and capital tax agreement of 30 January 1974
- Development date:
- 2026-10-22
The protocol replaces Article 10 of the 1974 agreement. Its dividend rule provides a 15% source-tax ceiling for qualifying beneficial owners and exemption for a resident beneficial-owner company, excluding partnerships, directly holding at least 10% of the payer’s capital for 365 days including payment day. Specified reorganisations do not interrupt that period; permanent-establishment-connected holdings have a separate rule.[2]
A principal-purpose test can deny treaty benefits, subject to its object-and-purpose exception. Groups should therefore assess ownership and anti-abuse conditions together, rather than treating a qualifying percentage alone as sufficient.[2]
Article 21 requires diplomatic notifications and sets entry into force on the first day of the second month after the later notification. Withholding changes generally apply to income paid or credited from the following 1 January; other taxes generally concern tax years starting then. No fixed application date has been established here.[2]
Official sources
- [1] Austria–Switzerland treaty protocol, dossier 615 d.B.
Austrian Parliament · Document date: 2026-10-22
Procedure rows 14 and 22 October: unanimous National Council approval and completed Federal Council no-objection and Länder consent. Extracted lines 65–105. Date is the parliamentary event, not page creation; no entry-into-force notification inferred.
- [2] Protocol amending the Austria–Switzerland agreement of 30 January 1974
Austria and Switzerland / Austrian Parliament · Document date: 2026-07-30
17-page normative protocol; focused root review of Article 7 replacing treaty Article 10, pp5–6; Article 16 principal-purpose test, p9; Article 18 closing-protocol direct-holding qualification, p11; Article 21 notifications/application, pp16–17 and dated signature p17. Worker reviewed full text; no whole current consolidated treaty review claim.