The income tax treaty between Switzerland and Austria (like the income tax treaty between Liechtenstein and Austria) not only provides for the taxation and reporting of current investment income by banks in Switzerland (and in Liechtenstein) to Austria, but also a regularization of the past.
Under these tax treaties, Austrian banking clients were required to choose between disclosing past assets and making an anonymous lump-sum payment. This option gave non-tax-compliant Austrian banking clients a chance to “wipe their slates clean” simply and anonymously by making a lump-sum payment of between 15% and 38% on any relevant capital.
These provisions for regularizing the past only applied specifically to Austrian banking clients who still held an account at a Swiss bank on 1 January 2013 or at a bank in Liechtenstein on 1 January 2014. Certain asset management structures in Liechtenstein were also covered by the tax treaty with Liechtenstein.
Read a July 2015 blog posting prepared by the KPMG member firm in Switzerland: Retroactive elimination of banking secrecy in Austria
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.