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.
Social security aspects of home office
Home office work, which was imposed by the authorities during the pandemic, gave an additional boost to teleworking and the associated flexibilization of work. Even after the pandemic, home office remains widespread in many areas. Employees appreciate the new flexibility and no longer want to do without it. This also applies to the numerous cross-border commuters. The following article clarifies social security issues in connection with home office, especially in cross-border situations.
Combating the misuse of letterbox companies
On 22 December 2021, the European Commission published a draft directive to combat the abusive use of letterbox companies within the EU. The directive, which is to be classified under ATAD III, imposes reporting obligations on letterbox companies and leads to the loss of tax benefits if certain substance criteria are not met.
Federal Council adopts dispatch on double taxation agreement with Zimbabwe
At its meeting on November 5, 2025, the Federal Council adopted the dispatch on the DTA with Zimbabwe.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on October 16, 2025 that the competent authorities of Switzerland and Germany have agreed to extend the consultation agreement on the application of Article 15 paragraph 4 of the double taxation agreement between Switzerland and Germany.
Signing and opening of the consultation on the protocol of amendment to the AEOI Switzerland-EU in tax matters
The Protocol of Amendment to the Agreement on the Automatic Exchange of Financial Account Information to Promote Tax Compliance in International Matters, signed on October 20, 2025, adapts the agreement to the amended OECD standard and supplements it with new provisions on administrative assistance in the collection of VAT claims. The consultation will last until February 6, 2026.
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.
Special problems of international tax planning of private investments, including international administrative and legal assistance in tax matters
Workshop on the occasion of the ISIS) seminar on 10-11 September 2018 entitled "Current Problems of Taxation of Private Investments".
Current questions on withholding tax and stamp duties, including international issues (2018)
Workshop on the occasion of the ISIS) seminar on 4-5 June 2018 entitled "Current problems and perspectives of corporate tax law".
