Austria: Protocol to Swiss treaty signed
Amending treaty to reflect OECD standards
Austria and Switzerland on July 30, 2026, signed a protocol amending their income tax treaty to reflect OECD standards, including the adoption of a preamble addressing treaty abuse and the introduction of a principal purpose test (PPT) to deny treaty benefits in cases of abusive arrangements.
The protocol also revises provisions on permanent establishments (PEs), residence of dual-resident entities, dividends, mutual agreement procedures (MAP), exchange of information, pensions, and international transport income, and updates the treaty's assistance in tax collection and dispute resolution provisions.
In addition, the protocol provides for a 0% withholding tax on qualifying intercompany dividends (10% ownership held for at least 365 days), dividends paid to pension funds, and dividends paid to the central bank of the other state, while most other dividends remain subject to a maximum 15% withholding tax.
For more information, contact a KPMG tax professional in Austria:
Markus Vaishor | mvaishor@kpmg.at