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New Switzerland–France Tax Amendment on Cross-Border Remote Work

Implementation of the amendment to the tax treaty between Switzerland and France: a sustainable framework for cross-border remote work taxation.

Services fiduciaires

Fiscalité

Table of contents

Introduction
Why Was This Amendment Considered Necessary?
What The Amendment On Remote Work Includes
Impacts for cross-border employees and employers
Broader tax adjustments

Introduction

Le 24 juillet 2025, un avenant important à la convention fiscale entre la Suisse et la France visant à éviter la double imposition est officiellement entré en vigueur. Cette mise à jour apporte des règles modernes et durables concernant l’imposition des revenus issus du télétravail, qui s’appliqueront à partir du 1er janvier 2026.

Why Was This Amendment Considered Necessary?

Faced with the rapid expansion of remote work, both countries recognized the need to adjust their bilateral tax treaty to this new reality. Since 2023, a temporary arrangement has already allowed cross-border workers to work remotely from France for up to 40% of their schedule without affecting their tax status. This amendment, initiated in June 2023, formalizes and secures this tax regime.

What The Amendment On Remote Work Includes

Remote work allowed up to 40% of working time: Employees living near the border can work remotely from France for up to 40% of their annual working time.
Taxation based on the employer’s country: Income from remote work will be taxed in the country where the employer is based.
Distribution of tax revenue: The employer will then transfer 40% of the taxes collected on this income to the employee’s country of residence.
Automatic data exchange system: To ensure accurate application of these rules, France and Switzerland will introduce, starting in 2027, an automatic exchange of salary data.

This new agreement therefore provides much-needed clarity in managing the taxation of cross-border remote work, a crucial issue in today’s remote work era.

Impacts for cross-border employees and employers

This amendment provides long-term peace of mind for employers and employees concerned with remote work between Switzerland and France. For employers, it means carefully tracking and recording the number of days or percentage of remote work performed by their staff, and complying with the necessary tax procedures with the authorities.

Impacts for cross-border employees and employers

Broader tax adjustments

Beyond remote work, this amendment modernizes several aspects of the tax treaty between Switzerland and France, aligning them with international best practices. In particular, it incorporates OECD recommendations aimed at preventing tax losses from certain strategies, known as base erosion and profit shifting (BEPS).