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 opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
Mutual agreement between Switzerland and Liechtenstein
On 02 March 2022, SIF announced the termination of the Mutual Understanding between Switzerland and Liechtenstein of 20/22 October 2020 on the impact of COVID-19 measures on the treatment of cross-border commuters under the DTA on 31 March 2022.
Tax relief for Ireland and the Philippines
On 25 February 2022, SIF updated the overview of the effects of the agreement on tax relief for Ireland and the Philippines.
Update of the overview of the effects of the agreement (extent of relief) concerning Australia
The State Secretariat for International Financial Matters (SIF) has updated the overview of the effects of the agreement (extent of relief) concerning Australia.
OECD publishes Transfer Pricing Guidelines
On 20 January 2022, the OECD published the latest version 2022 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Federal Council opens consultation on the automatic exchange of information with twelve other partner states
At its meeting on 3 December 2021, the Federal Council opened the consultation on the introduction of the automatic exchange of information on financial accounts (AEOI) with twelve additional states and territories.
Memorandum of Understanding between Switzerland and France
On 7 December, SIF announced that the mutual agreement between Switzerland and France of 13 May 2020 on the taxation of cross-border workers who work in the home office as a result of measures to combat Covid-19 will remain in force until 31 March 2022. Unless terminated by either party, it will then remain in force until 30 June 2022.
ISIS seminar folder "Gratuitous transfer of assets under tax law"
All documents from the ISIS) seminar "Gratuitous transfer of assets in tax law" from October 28, 2025 under the direction of Peter Mäusli-Allenspach in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following content description.
Practical examples of cross-border issues in relation to Germany
Case studies, slides and detailed solution notes from the workshop held by Hanna Brozzo and Iring Christopeit on October 28, 2025 on the occasion of the ISIS seminar "Gratuitous asset transfers in tax law".
