Switzerland generally does not enforce foreign-public claims, which also includes foreign tax claims. Art 26a of the Swiss-Austrian tax treaty however contains an exception to this rule, in the case of executable taxes on remuneration received by an Austrian resident from his or her employed work in Switzerland. Due to the narrow scope of this exception, Swiss case law related to this exception is very rare. A judgment from the Zurich District Court in 2020 highlighted certain procedural ambiguities in connection with the execution of such Austrian tax claims in Switzerland. Susanne Schreiber and Patrick Schmid address these ambiguities.
