The protocol amending the double-taxation agreement (DTA) between Switzerland and Hungary entered into force on 16 November 2025 but applies from 1 January 2026, bringing BEPS minimum standards and a new principal-purpose anti-abuse test into effect. The updated treaty clarifies residence tie-breakers, expands information-exchange clauses, and aligns the definition of permanent establishment with OECD standards.
For employers seconding staff between Zurich and Budapest’s growing fintech and pharma hubs, the key change is the removal of withholding tax on certain cross-border dividend payments when the beneficial owner holds at least 10 % of the paying company for one year. The protocol also redefines dependent personal-services rules, allowing employees to spend up to 183 days per any 12-month period in the host state before host-state taxation kicks in—previously the threshold was measured on a calendar-year basis, which created split-year complexities.
For companies managing short-term assignments and business-traveller rotations, ensuring that visa and work-permit paperwork aligns with the new tax thresholds is just as important as getting payroll right. VisaHQ’s Switzerland portal (https://www.visahq.com/switzerland/) provides real-time guidance and application services for Swiss, Hungarian and other Schengen visas, helping HR teams secure the correct documentation quickly and avoid compliance delays that could undermine the benefits of the revised treaty.
![Amended Switzerland-Hungary tax treaty enters into force, easing assignments]()
Mobility and payroll teams should update gross-up calculations and review assignment structures that relied on the old day-count methodology. Hungarian tax authorities have confirmed that certificates of coverage under the EU social-security coordination rules remain unaffected.
The Swiss State Secretariat for International Finance (SIF) recommends companies submit revised treaty-relief applications as soon as practical to avoid double withholding in Q1. Banks are upgrading their withholding systems to apply the new dividend rates automatically from the first distribution date in 2026.
While the protocol’s anti-abuse clause will make circular dividend routing harder, it provides greater legal certainty for genuine operational structures—especially relevant for the growing number of Swiss-based multinationals locating shared-service centres in Hungary.
For employers seconding staff between Zurich and Budapest’s growing fintech and pharma hubs, the key change is the removal of withholding tax on certain cross-border dividend payments when the beneficial owner holds at least 10 % of the paying company for one year. The protocol also redefines dependent personal-services rules, allowing employees to spend up to 183 days per any 12-month period in the host state before host-state taxation kicks in—previously the threshold was measured on a calendar-year basis, which created split-year complexities.
For companies managing short-term assignments and business-traveller rotations, ensuring that visa and work-permit paperwork aligns with the new tax thresholds is just as important as getting payroll right. VisaHQ’s Switzerland portal (https://www.visahq.com/switzerland/) provides real-time guidance and application services for Swiss, Hungarian and other Schengen visas, helping HR teams secure the correct documentation quickly and avoid compliance delays that could undermine the benefits of the revised treaty.
Mobility and payroll teams should update gross-up calculations and review assignment structures that relied on the old day-count methodology. Hungarian tax authorities have confirmed that certificates of coverage under the EU social-security coordination rules remain unaffected.
The Swiss State Secretariat for International Finance (SIF) recommends companies submit revised treaty-relief applications as soon as practical to avoid double withholding in Q1. Banks are upgrading their withholding systems to apply the new dividend rates automatically from the first distribution date in 2026.
While the protocol’s anti-abuse clause will make circular dividend routing harder, it provides greater legal certainty for genuine operational structures—especially relevant for the growing number of Swiss-based multinationals locating shared-service centres in Hungary.
