Entry into force of the additional agreement to the double taxation agreement between Switzerland and France
The additional agreement to the double taxation agreement between Switzerland and France entered into force on 24 July 2025. Its provisions, which permanently regulate the taxation of income from home office work, will apply from 1 January 2026.
The additional agreement is part of the solution agreed at the end of 2022 on the taxation of income from home office work. It provides for income from home office work to be taxed up to a limit of 40% of the working time per calendar year in the contracting state in which the employer is based. The new solution also provides that the employer's country will transfer 40% of the taxes it has levied on home office compensation in the employee's country of residence to the latter. Automatic exchange of information on wage data will ensure that the new rules are applied.
In addition, the additional agreement updates other provisions in the double taxation agreement between Switzerland and France. In particular, the additional agreement brings the double taxation agreement into line with the results of the OECD's work on base erosion and profit shifting (BEPS).
Address for enquiries:
Bilateral Tax Issues and Double Taxation Treaties Section, State Secretariat for International Finance SIF
Tel. +41 58 462 71 29, dba@sif.admin.ch