If you want to be ready for 2028, plan now.
Austria and Switzerland have comprehensively revised their double tax treaty (DBA, Doppelbesteuerungsabkommen). The amending protocol was signed on 30 July – the new rules are expected to apply from 2028.
Sounds a long way off? It isn't. The changes affect precisely the decisions being taken now:
- Moving to Switzerland: in future treated like a move within the EU – but only against security.
- Dividends: exemption from withholding tax from a shareholding of just 10 %.
- Permanent establishments: your sales activities may create one sooner than you would like.
- Credit method: will apply considerably more often.