Effective January 1, 2025, Swiss federal law on the taxation of remote work in an international context will strengthen the requirement for Swiss employers to monitor the remote working days and business trips of their cross-border employees (G-permit holders) using two certificates.
Update (17.12.2024) – The Federal Tax Administration announced that since the French Parliament has not ratified the Addendum to the Double Tax Treaty, a Mutual Agreement has been reached between the relevant authorities. This agreement extends the provisional rules for non-qualified French cross-border workers until December 31, 2025, delaying the start of information exchange for both qualified and non-qualified cross-border workers.
Certificate 1:
At the end of employment, cross-border workers (Swiss G-permit holders) can request their Swiss employer to provide a certificate detailing personal information, the number of remote working days, business trips in the country of residence or third countries, and overnight stays in Switzerland.
Update – Following conversations with the Secretariat for International Finance, it has been indicated that a model certificate from the Federal Tax Administration is being finalized and is expected to be published in early 2025. Employers should prepare to issue the first certificates by the end of January 2025 for employees leaving that month.
Certificate 2:
The tax agreements between Switzerland, Italy, and France on remote work require the exchange of specific information between the countries. Under the Federal Act on the Federal Direct Tax, Swiss employers must annually report data—such as the number of remote working days for French cross-border workers—to cantonal tax authorities. Detailed instructions on the transmission process are anticipated in the coming months.
Update – Certificate 2 will not apply in 2025, with the obligation postponed to 2026, assuming the French Parliament ratifies the Addendum in 2025. Nevertheless, employers must track employees’ workdays in 2025 to meet the requirements of Certificate 1 and ensure compliance with tax and social security regulations, as well as to prepare for 2026.
Action Required:
Swiss employers with cross-border employees (G-permit holders) must track remote working days and business trips to (1) issue the required certificates and (2) stay compliant with tax and social security regulations.
Nice to know links:
- Mutual Agreement between France and Switzerland regarding non-qualified cross-border workers: https://www.estv.admin.ch/dam/estv/fr/dokumente/international/laender/int-laender-fr-dba-aa-20241217-fr.pdf.download.pdf/int-laender-fr-dba-aa-20241217-fr.pdf
- Message on the Federal Act on the taxation of remote working in the international context : FF 2024 650 – Message relatif à la loi fédérale … | Fedlex
- Federal Act on the taxation of remote working in the international context: FF 2024 1453 – Loi fédérale sur l’imposition du … | Fedlex
- Amendment to the Source Tax Ordinance: https://www.newsd.admin.ch/newsd/message/attachments/90059.pdf
For more information or if you have any questions regarding French cross-border workers, please feel free to reach out to us for further discussion. Swiss Immigration Consulting (SIC) is here to support you.
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