Tax Implications of a Change of Residence Between Switzerland and Austria

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Switzerland and Austria are geographically close to each other, but their tax systems are not. A change of residence therefore involves more than just a change of address.

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Switzerland and Austria are geographically close to each other, but their tax systems are not. A change of residence therefore involves more than just a change of address.

When moving to Austria, the first question that arises is how the assets you bring with you will be valued for tax purposes. After that, the ongoing taxation of investment income and relief from withholding taxes come into play—both of which depend largely on the chosen ownership structure. Anyone who later returns to Switzerland will be subject to Austrian exit taxation, which the double taxation treaty only partially mitigates.

This article clarifies these interrelationships, takes into account the upcoming revision of the treaty, and illustrates them using a comprehensive case study.

Citation: Martin A. Meyer, Christian Fichtinger, Tax Implications of a Change of Residence Between Switzerland and Austria, in zsis) 3/2026, A10, N [...] (publ.zsis.ch/A10-2026)

Quarterly edition 3/2026

1. Introduction

Switzerland and Austria share a number of common factors—language, cultural proximity, comparable social values, and their immediate geographical proximity. This fosters intensive exchange between the two countries, not least in the form of changes in residence by individuals.

This article examines the tax implications of a change of residence between Switzerland and Austria. It provides a detailed analysis of both Austrian tax law and the double taxation treaty in eff

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