Cross-border worker taxes in Switzerland: who taxes you, and what that changes

The question a cross-border worker asks is not, first of all, "how much will I pay". It is "who has the right to tax me". Everything else follows from it: the payslip, the forms to fill in, the deductions available, and even the dates by which you must act.

This page is the entry point to the tax topic. It details neither the withholding tax codes, nor the correction procedure, nor the list of deductions: dedicated guides handle those, and section 8 tells you which one to read for each question. Its subject is the level above, the one almost everyone skips — working out which regime applies to you, and understanding what it requires of you for the year.

Contents of this guide:

• 1. Who has the right to tax you?
• 2. Resident of France: which regime applies in your canton?
• 3. Resident of Germany or Italy: which rules apply?
• 4. Teleworking: at what threshold does the tax move to another country?
• 5. What must you declare at home when Switzerland has already withheld tax?
• 6. Which exchange rate should you use in your tax return?
• 7. Which tax deadlines come round every year?
• 8. Which guide should you read for your specific question?
• 9. Frequently asked questions
• 10. What to remember

1. Who has the right to tax you?

Your starting regime, that is, whether Switzerland, your country of residence or both have the right to tax you, depends on two parameters: the canton where you work and the country where you live. The intersection of the two gives the State that collects.

This is why advice picked up between colleagues contradicts itself so often. A cross-border worker living in France and employed in Geneva, and another employed in Nyon twenty-five kilometres away, live under two different regimes — and what one of them did right may be precisely the other's mistake.

Starting regime, excluding excess teleworking and special statuses. The detail of the codes applied on the payslip is covered in our guide to Swiss withholding tax rates.

2. Resident of France: which regime applies in your canton?

As a resident of France, you are taxed in France, with no withholding on your salary, if you work in one of the eight cantons of the 1983 agreement, and at source in Switzerland if you work in Geneva or in another canton outside the agreement. This is the least well known fork in the road, and the one that produces the most unpleasant surprises in the first year.

The eight cantons of the 1983 agreement

The Franco-Swiss agreement of 11 April 1983 covers Bern, Solothurn, Basel-Stadt, Basel-Landschaft, Vaud, Valais, Neuchâtel and Jura. If you live in France and work in one of them, your salary is paid to you with no tax withheld at all, and it is taxed in France.

That comes at a price, in two parts. First, a formality: your employer needs a certificate of tax residence to justify withholding nothing. Second, and this is what catches people out, you receive a salary free of tax all year and you pay the French tax afterwards. A salary that looks comfortable in January has not yet met its tax bill.

Geneva and the cantons outside the agreement

Here the canton withholds the tax at source, directly on the payslip. The salary arrives free of Swiss tax, and you have nothing to advance.

But that withholding is a flat-rate one: it is calculated on a scale that assumes a standard family situation and ignores most of your actual expenses. Two procedures allow it to be corrected — the rectification and the subsequent ordinary assessment, both locked into a strict deadline. That is the subject of our guides dedicated to correcting withholding tax in Geneva and to quasi-resident status.

Take away just one point here, the one that fixes your calendar: the application must be filed by 31 March of the following year at the latest, and that deadline cannot be made up.

3. Resident of Germany or Italy: which rules apply?

As a resident of Germany, you are taxed in Germany and the Swiss withholding is capped at 4.5%, provided you keep cross-border status and submit the Gre-1 form; as a resident of Italy employed in Ticino, Graubünden or Valais, your regime depends on the 2020 agreement and on your category, former or new cross-border worker. These two borders do not follow the French pattern: if you live in Germany or in Italy, the preceding paragraphs do not describe your situation.

Residents of Germany

The canton withholds at most 4.5% of gross salary (art. 15a of the Switzerland-Germany double taxation convention), and the tax is due in Germany, the Swiss withholding being credited against German tax. Cross-border status assumes a regular return home. Since 1 January 2026, the protocol amending the convention defines it as follows: you travel from your home to your place of work, and back, on at least 20% of the agreed working days in the calendar year. Days teleworked from home do not count as days of non-return, and neither do non-returns for private reasons — holidays, illness, weekends.

That 4.5% cap assumes two cumulative conditions: regular return to the German home — commuting on at least 20% of the agreed working days, and no more than 60 days of non-return for professional reasons in the calendar year — and submission to the employer of the Gre-1 form, a certificate of residence issued by the German tax authorities. If either of the two is missing, the withholding is no longer capped at 4.5%: the ordinary Swiss rates apply, at rates far above that 4.5%. That 4.5% is not refundable: it is credited against German income tax.

Residents of Italy

The agreement between Switzerland and Italy of 23 December 2020, which entered into force on 17 July 2023, created two categories, and the arrangement concerns only three cantons: Ticino, Graubünden and Valais.

Former cross-border workers — those who worked in one of those three cantons between 31 December 2018 and 17 July 2023 — stay on the ordinary rates and are taxed in Switzerland only. New cross-border workers face a Swiss withholding limited to 80% of what it would be under the ordinary rates, with Italy then taxing the income and eliminating double taxation. Their income enters the Italian tax base after an exemption of €10,000. Our guide to Swiss withholding tax rates details the codes applied in each case. To find out which category you fall into, and what each one means in Switzerland and in Italy, read our guide on existing and new Italian cross-border workers.

The heaviest practical consequence concerns recourse: for a cross-border worker covered by the agreement, former or new, withholding at source is final. The agreement rules out any other method of taxation, and the federal Withholding Tax Ordinance expressly closes off the subsequent ordinary assessment to these cross-border workers. The 31 March mentioned above therefore does not open that route for them.

4. Teleworking: at what threshold does the tax move to another country?

The teleworking threshold beyond which the tax moves to another country is 40% of annual working time for a resident of France and 25% for a resident of Italy; for a resident of Germany there is no cap, but you must go to your place of work on at least 20% of the agreed working days. This is where the greatest number of cross-border workers go wrong, because the figure in circulation varies from one country to another.

Applying 40% while living in Italy means exceeding your cap by fifteen points. The figure of 40% is the most quoted because it concerns the greatest number, not because it is the general rule. Nor does it apply to Germany, where no tax text sets a teleworking cap. For Italy, our guide to telework for cross-border workers living in Italy explains the 25% rule in detail.

Resident of France: one threshold, two mechanisms. In the eight cantons of the 1983 agreement, a mutual agreement has allowed teleworking of up to 40% since 2023 without losing cross-border status; that quota includes no more than ten days of temporary assignments in France or in a third country. In Geneva and the other cantons outside the 1983 agreement, the 2023 amendment to the tax convention, applicable since 1 January 2026, leaves the taxation of teleworking up to 40% to Switzerland; beyond that, France taxes every day teleworked, from the first. Our guide to cross-border teleworking details both cases.

Resident of Germany: no cap, but a minimum of presence. The salary of a cross-border worker within the meaning of the convention is taxed in Germany, and the Swiss withholding remains limited to 4.5%, whether you work at the office or at home. What is at stake is keeping the status: commuting to the place of work on at least 20% of the agreed working days, that is one day a week for a full-time job, and not exceeding 60 days of non-return for professional reasons. An employee who loses that status comes under the general rule: Switzerland taxes the days worked on its territory at the ordinary rates, Germany those worked in Germany, teleworking included, and no tolerance is provided between the two countries.

In every case, crossing the limit does not result in a penalty but in a shift in the right to tax. In Geneva and the other cantons outside the agreement, as well as for a resident of Italy, the State of residence then taxes the share of pay corresponding to the days teleworked. In the eight cantons of the 1983 agreement, the cross-border worker loses the status for the whole year: Switzerland taxes at source the salary for the days worked on its territory.

Social security follows another threshold, common to all three countries. The multilateral framework agreement on teleworking, in force since 1 July 2023 (1 January 2024 for Italy), allows teleworking of up to 49.9% of working time from France, Germany or Italy while remaining insured in Switzerland, provided the employer applies for an A1 certificate. Below 25%, the ordinary rules of European coordination apply and already keep you affiliated in Switzerland.

5. What must you declare at home when Switzerland has already withheld tax?

Even when Switzerland has already withheld the tax, a resident of France must report their Swiss salary in their French return, and a resident of Germany is taxed in Germany, the Swiss withholding being credited against German tax. One false idea costs dear every year: "Switzerland has already withheld, so I have nothing to declare".

For a resident of France taxed at source in Switzerland, the Swiss income is reported in the French return. That reporting does not make you pay twice: it serves to determine the rate applicable to your other income, and it conditions everything calculated on your reference taxable income.

For a resident of Germany, the mechanism is different: Germany taxes the Swiss salary, the Swiss withholding being credited against German tax. The income is not merely taken into account for the rate there, it is taxed there.

The Italian case is different again. Former cross-border workers within the meaning of the 2020 agreement are taxed in Switzerland only; new cross-border workers face a Swiss withholding limited to 80% of the ordinary rates, with Italy then taxing the income and eliminating double taxation.

Your accounts held abroad

This is an obligation distinct from the income tax return, and it is often discovered too late.

Two clarifications are worth setting down, because they are behind most oversights. First, the French obligation covers accounts opened, held, used or closed: an account closed during the year still has to be declared for that year. Second, it is not limited to accounts opened with a bank — payment accounts fall within its scope. If in doubt about a particular account, the question goes to your French public finance office, not to the institution that holds it.

The automatic exchange of information between Switzerland and neighbouring States also makes these accounts visible to the tax authorities of your country of residence. Declaring is not reporting yourself: it is regularising information that has already been transmitted.

6. Which exchange rate should you use in your tax return?

You are paid in francs and you declare in euros. Between the two there is a rate — and it follows a method. What follows applies to a resident of France; Germany and Italy have their own conversion rules.

The French tax authorities publish an average exchange rate for the year, used in form 2047-Suisse. For 2025 income, it was set at 1.07 EUR to 1 CHF. That is the reference rate for converting your salary. You may prefer the rate on the day of receipt if it is more favourable to you, provided you apply the same method to all of your income and can document it.

Two rates are worth telling apart, because they are readily confused. The declaratory rate serves to convert income on paper. The actual conversion rate applies to the money you really bring home each month to live on, pay your bills or settle your tax. The first follows a method that must be held to across the year; the second depends on your provider.

On that second point, the differences between providers lie in the margin applied to the market rate. Our guide to calculating an exchange rate explains how to read it, and our guide to transferring a Swiss salary details the gaps observed between providers.

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7. Which tax deadlines come round every year?

The exact dates vary from one year to the next, but the order of the deadlines does not move. Here is the outline to know, for a resident of France.

Indicative outline for a resident of France, except for the last line, which applies to all three countries of residence. The precise dates of the filing season are published each year by the tax authorities; check them before acting.

Only one of these lines is irreversible: 31 March. The other deadlines can be made up, with a surcharge or a claim. That one cannot.

8. Which guide should you read for your specific question?

Once you have identified your regime, each practical question has its own guide. Start from the question you are asking yourself, not from the name of the procedure.

9. Frequently asked questions

Am I taxed in Switzerland or in my country of residence?

It depends on your canton of work and your country of residence. If you live in France and work in one of the eight cantons of the 1983 agreement — Bern, Solothurn, Basel-Stadt, Basel-Landschaft, Vaud, Valais, Neuchâtel, Jura —, your salary is paid with no withholding and taxed in France. If you work in Geneva, the canton withholds at source. Residents of Germany come under a Swiss withholding capped at 4.5% with taxation in Germany, and residents of Italy under the agreement of 23 December 2020 depending on whether they are former or new cross-border workers. This page is informational and constitutes neither legal advice, nor tax advice, nor personalised advice: determining your regime is a matter for the competent authority or a professional.

How many days can I telework without changing regime?

It depends on your country of residence. Resident of France: 40% of annual working time, meaning about two days a week for a full-time job. Resident of Italy: 25%, meaning about one day a week. Resident of Germany: no percentage cap on teleworking; since 2026, cross-border status requires commuting to the place of work on at least 20% of the agreed working days, and days teleworked from home do not count as days of non-return. On the social security side, a separate rule applies to all three countries: up to 49.9% teleworking with no change of affiliation, on the employer's application for an A1 certificate.

Does teleworking from Germany cost me my cross-border status?

No, as long as you travel from your home to your place of work in Switzerland on at least 20% of the agreed working days in the calendar year. This rule is set out in the protocol amending the German-Swiss convention, applicable since 1 January 2026. Full days teleworked from home do not count towards the 60 days of non-return for professional reasons. Teleworking therefore does not change which State taxes you: Germany taxes the salary, Switzerland withholds at most 4.5%. If you lose the status, Switzerland taxes the salary for the days worked on its territory at the ordinary rates, instead of the 4.5% withholding, and Germany taxes the salary for the days worked there, teleworking included; senior executives of a Swiss company come under a special rule. No teleworking tolerance is provided between the two countries for this case.

How many days can I spend away from home without losing cross-border status?

The cap depends on your country of residence. Resident of France employed in one of the eight cantons of the 1983 agreement: 45 nights a year away from France, at most one per working week. Resident of Germany: 60 days of non-return for professional reasons per calendar year. Resident of an Italian municipality in the 20 km zone employed in Ticino, Graubünden or Valais: 45 days per calendar year. Teleworking days do not enter these counts; our guide to non-return days details what counts and what does not.

Must I declare my Swiss salary in France if Switzerland has already taxed it?

Yes. The Swiss income is reported in the French return even where Switzerland has withheld at source. That reporting does not result in double taxation: it determines the rate applicable to your other income and feeds your reference taxable income, which serves as the basis for many benefits.

Which exchange rate should I use to declare my income in France?

For a resident of France: the annual average exchange rate published by the French tax authorities, used in form 2047-Suisse. For 2025 income, it was set at 1.07 EUR to 1 CHF. You may prefer the rate on the day of receipt if it is more favourable to you, provided you apply the same method to all of your income and can document it. Germany and Italy have their own conversion rules.

What is the risk of not declaring an account held abroad?

In France, the fine provided for is €1,500 per account and per undeclared year, raised to €10,000 where the account is located in a country with no administrative assistance treaty. The obligation covers accounts opened, held, used or closed, and is not limited to bank accounts: payment accounts fall within its scope. In Italy, the obligation runs through the Quadro RW of the Modello Redditi. Germany does not require the existence of the account to be declared, but does require investment income to be declared in the Anlage KAP.

Does an account closed during the year have to be declared?

Yes, for a resident of France: form 3916-3916 bis covers accounts opened, held, used or closed during the year. An account closed in March still has to be declared for the year concerned.

Why is my tax going up when my salary has not moved?

Because your salary is converted into euros for your return. If the franc strengthens, the euro value of your pay rises without the amount in francs having changed. Your reference taxable income goes up, which can change your tax bracket and the benefits calculated on that income.

What is the date not to miss?

31 March, for cross-border workers taxed at source who can apply for a rectification or a subsequent ordinary assessment. That second route is closed to cross-border workers living in Italy who come under the 2020 agreement, former and new alike. It is the only deadline in the cross-border worker's tax calendar that cannot be made up: after that date, the correction is no longer admissible for the year concerned.

What can a Geneva quasi-resident deduct in 2026?

The subsequent ordinary assessment opens up the deduction of actual expenses: travel, meals, childcare, maintenance payments, buy-backs into the 2nd pillar and contributions to pillar 3a. For 2026, pillar 3a is capped at 7,258 francs for an employee affiliated to a pension fund — which is the case of a cross-border worker employed in Switzerland. The cap of 36,288 francs is reserved for self-employed people with no 2nd pillar. Access depends on the share of gross worldwide income, including the spouse's, that is taxable in Switzerland; our guide dedicated to quasi-resident status details the calculation, and our guide to the cross-border worker's tax deductions gives the full list.

Is my Swiss salary subject to CSG-CRDS?

For a resident of France, no. Your salary comes under Swiss social security, and the Court of Justice of the European Union held, in the de Ruyter judgment, that CSG and CRDS contribute to financing French social security: they therefore cannot be levied on that salary, even if you have opted for French health insurance. In that case, however, the Urssaf collects the cross-border worker's health contribution: 8% in 2026, after an allowance of €12,015. On income from assets, for example rental income, a cross-border worker who stayed with LAMal pays only the 7.5% solidarity levy; a cross-border worker affiliated to French health insurance remains liable for CSG and CRDS under a strict reading of the form, which cross-border workers' associations dispute. Our guide to CSG-CRDS and the cross-border worker's health contribution details the calculation.

Can I deduct my pillar 3a payments?

You can contribute as soon as your salary is subject to the AVS, up to 7,258 francs in 2026 with a pension fund. Deducting those payments is rarer. Taxed at source, you can only do so through a subsequent ordinary assessment, reserved for quasi-residents at least 90% of whose household worldwide income is taxable in Switzerland, and applied for by 31 March at the latest. A resident of France employed in the eight cantons of the 1983 agreement, a resident of Germany or a resident of Italy covered by the 2020 agreement has, in practice, no Swiss deduction. Our guide to pillar 3a for cross-border workers examines each case.

10. What to remember

Cross-border taxation is not complicated because the rules would be obscure. It is complicated because several regimes coexist along the same border, and advice that is right for a colleague may be wrong for you. Before applying a rule you read somewhere, ask yourself the only two questions that matter: which canton do I work in, which country do I live in.

Three reflexes cover the essentials: keeping the right day count for your country of residence, not letting 31 March go by if you are taxed at source and the subsequent ordinary assessment is open to you, and declaring your accounts even closed ones, even non-bank ones.

Other references. Agreement between Switzerland and Italy on the teleworking of cross-border workers for the 25% threshold; for residents of Germany, German-Swiss mutual agreement of 15 and 18 July 2022 (days teleworked from home excluded from days of non-return) and Bern tax administration information sheet Q12 on German cross-border workers from 2026; form 2047-Suisse for the annual average exchange rate; French general tax code, art. 1649 A and art. 1736 IV, for form 3916-3916 bis and the fines of €1,500 and €10,000; quadro RW of the Modello Redditi and IVAFE for Italy; Anlage KAP for Germany; pillar 3a caps published by the FTA for 2026.

Disclaimer. This page is informational and constitutes neither legal advice, nor tax advice, nor personalised advice. The rules change and their application depends on your situation. For a binding decision, contact a professional or the competent authority in your country of residence. The rules cited here for France, Germany and Italy are cited in respect of their own country and are not transposable from one country to another.