Taxation of employees in the case of cross-border work in the home office
Sarah Bühler, René Matteotti and Peter Vogt address the taxation of international employees and their home office activities. They provide an overview of the existing regulations and pay particular attention to the cross-border commuter agreements with Switzerland's neighboring countries.
Implications of the home office for cross-border commuters between Switzerland and Germany
Working from home has become much more important due to the Corona pandemic. Many employers have found that working from home has proven successful and have introduced regulations that enable mobile working. This also affects cross-border commuters between Germany and Switzerland. A variety of tax regulations, especially in the DTA D-CH, as well as consequences under social security law must be taken into account.
Home office and the cross-border commuter agreement with Italy
Today, around 85,000 Italian residents work in the border cantons of Ticino, Grisons and Valais. The cross-border commuter agreement concluded with Italy is of great importance especially for the canton of Ticino with its approximately 75,000 cross-border commuters, of which around 66,000 are considered cross-border commuters within the meaning of the agreement.
Cross-border commuter regulation Switzerland-Liechtenstein
The double taxation agreement between Switzerland and Liechtenstein contains a special rule for cross-border commuters, according to which the income from employment earned in the State of activity is allocated to the State of residence for taxation. If, on the other hand, an employee in a cross-border context does not meet the criteria established for cross-border commuters, the earned income is allocated for taxation to the State of activity and the State of residence on a pro rata basis in accordance with the general principles. Against this background, employers who employ cross-border commuters from Liechtenstein or Switzerland have different clarification and declaration obligations.
Federal Council adopts dispatch on the exchange of information on OECD minimum taxation
At its meeting on September 12, 2025, the Federal Council adopted the dispatch on the approval of the international legal basis for the exchange of information for OECD minimum taxation.
Federal Council opens consultation on AEOI with 8 other partner states
At its meeting on August 13, 2025, the Federal Council opened the consultation on the introduction of the automatic exchange of financial account information (AEOI) with 8 additional countries. The AEOI with these partner states is scheduled to enter into force on January 1, 2027.
Supplementary tax: Date of application of the safe harbor rules on hybrid arbitrage arrangements in accordance with the administrative guidelines of December 18, 2023
The FTA announces that the rules regarding hybrid arbitrage arrangements under the temporary CbCR safe harbor of the administrative guidance of December 18, 2023 will apply to transactions after December 18, 2023.
Entry into force of the supplementary agreement (in particular home office) to the double taxation agreement between Switzerland and France
The supplementary agreement to the double taxation agreement between Switzerland and France entered into force on July 24, 2025.
Entry into force of the protocol of amendment to the double taxation agreement with Serbia
The protocol of amendment to the double taxation agreement (DTA) between Switzerland and Serbia entered into force on July 18, 2025. With a few exceptions, most of the amendments will apply from January 1, 2026.
Switzerland and Croatia sign protocol of amendment to double taxation agreement
On July 18, 2025, Switzerland and Croatia signed a protocol of amendment to the double taxation agreement (DTA) in the area of taxes on income and capital.
Supplementary tax: crediting of residual tax as the relevant tax for Swiss supplementary tax
On 24 July 2025, the FTA published a notice stating that the crediting of the residual tax as the relevant tax for Swiss supplementary tax is recognized as part of the minimum taxation of multinational groups of companies.
Current cases on intercantonal and international corporate tax law
Workshop by René Matteotti and Philipp Betschart at the ISIS) seminar on 13/14 June 2022 entitled "Corporate Tax Law 2022".
Taxation of spouses in international relations
Workshop by Ah and Petra Caminada on the occasion of the ISIS) seminar on 16 November 2021 entitled "Marriage, Partnership and Family in Tax Law".
