Switzerland and Austria sign protocol of amendment to double taxation agreement
On 30 July 2026 in Vienna, Switzerland and Austria signed a protocol amending the agreement for the avoidance of double taxation (DTA) with respect to taxes on income and capital. The protocol implements the minimum standards set out in the agreement for double taxation and makes specific adjustments to the DTA to bring it into line with the changing needs of the contracting states since the last revision, which was carried out under the 2009 protocol of amendment.
The protocol implements the BEPS minimum standards for double taxation agreements. It contains an anti-abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused. Furthermore, the protocol of amendment resolves differences of interpretation between the contracting states, for example regarding retirement provisions for public sector employees and social security, [RC1] improves the conditions for cross-border investment by adjusting the treatment of dividends, and clarifies the procedure for the enforcement of tax claims relating to the wages of cross-border commuters.
The cantons and the business circles concerned have welcomed the conclusion of the protocol of amendment. It still has to be approved by the legislator in both countries before it can come into force.
Address for enquiries
Bilateral Tax Issues and Double Taxation Treaties Section, State Secretariat for International Finance SIF
Tel. +41 58 462 71 29, dba@sif.admin.ch.