Zürich

LeitnerLeitner Zürich AG

tax audit advisory

CH 8001 ZÜRICH, Selnaustrasse 6
t +41 44 226 36 10 f +41 44 226 36 19
e zuerich.office@leitnerleitner.com

Zürich

Our services in Switzerland

Our address:

LeitnerLeitner Zürich AG
CH 8001 Zürich,
Selnaustrasse 6

T +41 44 226 36-10

F +41 44 226 36-19
E zuerich.office@leitnerleitner.com

Options for taxpayers under the Austria-Switzerland tax agreement

In addition to the existing option to make a voluntary disclosure, the agreement also provides two further options for individual taxpayers:

  • Anonymous lump-sum payment: the taxpayer wishes to remain anon-ymous. The bank in Switzerland calculates the lump-sum tax payment on assets invested according to a complex formula provided by the tax agreement and transfers the lump-sum payment via the Swiss tax administration to the Austrian tax authorities. The taxpayer receives a confirmation from the Swiss bank that he or she has made the lump-sum payment. The taxpayer's past tax commitments are deemed to have been settled as a result and an amnesty is granted for any associated tax offences.
  • Voluntary notification: the taxpayer decides to disclose his or her financial assets held in a (securities) account with a bank in Switzerland to the Austrian tax authorities. The Swiss bank notifies the assets or the funds held to the Swiss tax administration, which informs the Austrian tax authorities. The voluntary notification has the same effect as a voluntary disclosure, protecting the taxpayer from sanctions provided that the taxpayer discloses the corresponding tax base within an appropriate period of time to be set by the tax office to the tax authorities and that the tax is paid within one month of notification of the tax assessments.

Cold repatriation or tax evasion is not advisable under any circumstances! The taxpayer will not be able to make use of the benefits of the tax agreement and he/she must continue to expect tax assessments and criminal prosecution!

Contact person
 Dr.

Roman Leitner

Dr.
Auditor | Tax advisor | Partner (em.)

Criminal tax law, litigation, succession planning...
Dr.

Rainer Brandl

Dr.
Tax advisor | Partner

Austrian tax law, criminal tax law, litigation/procedural law, tariff law...

Matthias Hofstätter


Tax Advisor | Partner

Austrian and international tax law, financial products, banks and insurance companies, investment income, investment...
Dr.

Yvonne Schuchter-Mang

Dr.
Tax Advisor | Partner

Taxation of foundations and trusts, international tax law, taxation of financial instruments, high net worth...