Switzerland

IFD, cantons and communes, tax liability, lump-sum taxation, withholding tax, anticipatory tax, companies and the OECD, VAT, wealth, inheritances and the France–Switzerland treaty.

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TAX FACTSHEET · 2026-09-26

In this factsheet

Personal and business taxation in Switzerland

Documentary position as at 26 September 2026. The federal rules cited are those of the consolidated versions published on Fedlex applicable at that date; cantonal data come from the brochures of the Swiss Federal Tax Administration (AFC) for the 2025 tax period or from the cantonal texts consulted, and their reference year is stated in each case.

1. Identifying the level of government, the canton and the year

1. In Switzerland, the same income may be subject to three levels of taxation: the direct federal tax (IFD), the cantonal tax and the communal tax. The Constitution authorises the Confederation to levy direct taxes within rate limits, while the LHID designates the taxes that the cantons must levy and expressly leaves to the cantons the setting of scales, rates and exempt amounts. No single “Swiss” rate can therefore be derived from the federal texts alone. S01 S03

2. The LHID requires the cantons to levy an income and wealth tax on individuals, a profit and capital tax on legal entities, a withholding tax and a real estate gains tax. The communes tax only to the extent that cantonal law grants them that power. For a given taxpayer, the canton and commune of attachment must therefore be identified before any calculation; the Geneva and Vaud examples given in this factsheet do not apply to the other cantons. S03 S16

3. The Constitution sets the federal ceilings: 11.5% on the income of individuals and 8.5% on the net profit of legal entities. A transitional provision limits the levying of the IFD, like that of VAT, to the end of 2035. These ceilings concern the federal level only and do not represent a taxpayer’s total tax burden. S01

4. The IFD amounts applicable to individuals are adjusted to the price index. The DFF Ordinance of 10 September 2025 on cold progression, in force since 1 January 2026, amended the scales in Article 36 LIFD and the minimum amount for taxation according to expenditure. The 2026 federal figures given below come from that ordinance and from the consolidated LIFD; the AFC cantonal tables used further on relate, by contrast, to the 2025 tax period. S02 S04 S26

5. The timetable must also be checked for reforms that have been adopted but are not yet applicable. Fedlex already publishes a version of the LIFD applicable on 1 January 2029, in which the taxation of the imputed rental value of owner-occupied housing is repealed by the Federal Act of 20 December 2024 on the change of system for the taxation of residential property. As at 26 September 2026, the version of the LIFD in force still refers to that imputed rental value. S02 S13

2. Tax liability of individuals, arrival and departure

6. Within the meaning of the LIFD, an individual is liable to tax by reason of personal attachment when he or she is domiciled or staying in Switzerland. Tax domicile requires residence with the intention of settling permanently, or a special legal domicile provided for by federal law. It is therefore not a mere count of days. S02

7. Tax stay is defined by two alternative thresholds, assessed “without significant interruption”: at least 30 days while carrying on a gainful activity, or at least 90 days without a gainful activity. A person who keeps his or her domicile abroad and resides in Switzerland solely to attend an educational institution or to receive medical treatment is neither domiciled nor staying for tax purposes. The LHID adopts the same thresholds for cantonal tax liability. S02 S03

8. Tax liability by reason of personal attachment is unlimited, subject to the items that federal law allocates abroad, in particular businesses, permanent establishments and immovable property situated outside Switzerland. Conversely, a non-resident may be liable to tax by reason of economic attachment, in particular if he or she is the owner or usufructuary of a business or of immovable property situated in Switzerland, operates a permanent establishment there or deals in Swiss immovable property. S02 S16

9. The income and wealth of spouses living in a joint household are aggregated, whatever the matrimonial property regime, and those of children under parental authority are added to those of the holder of that authority, except in particular the proceeds of their gainful activity. This rule, laid down by the LHID for cantonal taxes, has an equivalent in the LIFD. It also governs the application of certain regimes, such as taxation according to expenditure, which requires both spouses to meet the conditions. S02 S03 S17

10. Tax liability begins on the day on which domicile is taken up or the tax stay begins, or on the day on which a taxable item is acquired; it ends on the day of death, of departure from Switzerland or of the disappearance of the taxable item. The LIFD exempts capital gains realised on the disposal of private assets, and the texts consulted do not provide for any general taxation of unrealised gains on private assets when an individual departs. This finding does not apply to business assets: the transfer of business assets to a business or permanent establishment abroad is treated as a disposal. S02 S16

11. Departure also calls for an examination of the host State and, where relevant, of the applicable treaty. For France, Article 4 of the treaty of 9 September 1966 provides that, in the event of a permanent transfer of domicile, liability to the taxes dependent on domicile ceases in the first State at the end of the day of the transfer and begins on the same day in the other State. This treaty rule does not, on its own, resolve questions of French domestic law such as any exit tax. S11

3. Income tax: IFD and cantonal and communal taxes

12. Income tax covers all income, whether one-off or periodic, including benefits in kind. Taxable income includes, in particular, the proceeds of employed or self-employed activity, the yield on movable and immovable assets and pension income. Capital gains realised on private movable assets are not taxable, either at federal level or, according to the AFC, at cantonal level; private real estate gains, by contrast, are subject to a special cantonal tax, examined in section 8. S02 S03 S16

13. The yield on movable assets includes, in particular, interest, dividends, liquidation surpluses and other monetary benefits derived from participations. For the IFD, 70% of these distributions are taxable where the participation rights represent at least 10% of the capital. The LHID requires the cantons to tax at least 50% in the same case, and the cantons may provide for higher taxation. The repayment of reserves from capital contributions is treated, subject to conditions and limits, as a repayment of capital. S02 S03

14. Certain disposals of private participations are recharacterised as investment income. The LIFD covers, in particular, the sale of a participation of at least 20% to a person who places it in business assets, where substance not required for operations is distributed within five years with the seller’s involvement, as well as certain contributions of participations to a company that is at least 50% controlled. The exemption of private gains is therefore not absolute. S02

15. The 2026 federal scale applicable to single persons starts above CHF 15,200 of taxable income and rises in brackets up to a marginal rate of 13.20%; from CHF 794,000, the tax is CHF 11.50 per CHF 100, i.e. a uniform rate of 11.5% on the whole of the income. For married couples and the persons referred to in Article 36, paragraph 2, LIFD, the scale starts above CHF 29,700 and the 11.5% rate applies from CHF 941,400. The paragraph 2 scale also applies, by analogy, to widowed, separated, divorced or single taxpayers living in a joint household with children or dependent persons whose maintenance they essentially provide. For all the taxpayers referred to in paragraph 2bis, including spouses living in a joint household, the tax is reduced by CHF 263 per child or dependent person; this reduction is excluded in the case of taxation according to expenditure. S02 S04

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2026 IFD scale (art. 36 LIFD as amended by the OPFr)	Single persons (para. 1)	Married couples and persons treated as such (para. 2)	Sources
Taxable income below which no tax is due	CHF 15,200	CHF 29,700	S04
Highest marginal rate before the final bracket	13.20% above CHF 185,100	13.00% above CHF 152,400	S04
Threshold from which all income is taxed at 11.5%	CHF 794,000	CHF 941,400	S04 S02
Constitutional ceiling	11.5%	11.5%	S01

16. Cantonal and communal income taxes follow the harmonised framework of the LHID, but their scale, their annual coefficient and the quantified deductions are a matter for cantonal law. The AFC notes that these taxes are similar in structure but that the cantons remain free to set the rates. The cantonal and communal burden is added to the IFD; the rules of attachment and allocation between cantons must be checked in the event of a change of domicile or of assets situated in several cantons. S03 S16 S17

17. Lump-sum benefits from occupational pension schemes and from tied individual pension schemes are taxed separately, for the year in which they accrue, at rates representing one fifth of the ordinary scales for the IFD. This separate regime must not be confused with the taxation of pensions paid as annuities, which form part of ordinary income. The cantons have a separate taxation mechanism whose quantified terms are specific to each of them. S02 S03

4. Taxation according to expenditure (lump-sum taxation)

18. Taxation according to expenditure replaces income tax for the IFD. It is available to persons who do not have Swiss nationality, who are subject to unlimited tax liability for the first time or after an absence of at least ten years, and who do not carry on a gainful activity in Switzerland. Spouses living in a joint household must both meet these conditions. S02 S35

19. The base consists of the annual expenditure of the taxpayer and of the persons dependent on him or her, in Switzerland and abroad, to maintain their standard of living. For the IFD, it may not be lower than the highest of the following amounts: CHF 435,000 per year since 1 January 2026; seven times the annual rent or the imputed rental value for a head of household; three times the annual price of board and lodging for other taxpayers; and the sum of certain gross income from Swiss sources or for which treaty relief is claimed. The tax is then calculated according to the ordinary scale. The version of the LIFD applicable on 1 January 2029 already refers to a DFF ordinance of 11 September 2026 raising that amount to CHF 437,000 from 1 January 2027. S02 S04 S13

20. This last control calculation is of considerable practical importance. It includes, in particular, income from immovable property situated in Switzerland and from movable capital invested in Switzerland, Swiss-source pensions and income for which the taxpayer claims relief from foreign taxes under a treaty concluded by Switzerland. Where a foreign State exempts an item of income only on condition that Switzerland taxes it at the rate applicable to total income, all items of income arising in that source State and allocated to Switzerland by the treaty concerned are also included in the calculation. S02 S05

21. For cantonal taxes, the LHID allows the canton to grant taxation according to expenditure under the same personal conditions, with a minimum amount set by the canton. The tax according to expenditure then replaces income tax and wealth tax, the cantons determining how it covers the latter. The amount due must at least equal the sum of income and wealth taxes calculated at the ordinary scale on certain gross items from Swiss sources. S03 S26

22. The regime does not exist in all cantons. According to the AFC 2025 brochure, Zurich, Basel-Stadt, Schaffhausen and Appenzell Ausserrhoden do not have taxation according to expenditure, and Basel-Landschaft allows it only on arrival, until the end of the current tax period. The Federal Department of Finance recalls the Zurich abolition approved by popular vote in 2009 and the federal tightening that entered into force in 2014 for the LHID and in 2016 for the LIFD. S26 S35

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Lump-sum taxation: minimum amount of the “income” base (AFC brochure, 2025 tax period)	Minimum amount or position	Coverage of wealth stated by the AFC	Sources
Confederation (IFD)	CHF 434,700 in 2025; CHF 435,000 since 1 January 2026	No federal wealth tax	S26 S04
Geneva	CHF 425,194	Amount used for income increased by 10%	S26
Vaud	CHF 415,000, including a 15% increase covering wealth	Increase of the amount used for income	S26
Valais	CHF 250,000	At least four times the amount used for income	S26
Zurich, Basel-Stadt, Schaffhausen, Appenzell Ausserrhoden	No taxation according to expenditure	Not applicable	S26

23. Lump-sum taxation is not an exemption regime. The tax is calculated at the ordinary scale on a base determined differently, and the taxpayer remains subject to the other taxes that are not replaced, for example cantonal inheritance taxes. In Geneva, the Inheritance Duties Act disapplies the exemption for the spouse and descendants where the deceased benefited from taxation according to expenditure under one of the last three final assessment decisions. S02 S27 S32

24. At treaty level, Article 4, paragraph 6, letter b, of the France–Switzerland treaty excludes from resident status an individual who is taxable in Switzerland only on a lump-sum basis determined by reference to the rental value of his or her residences. The scope of this exclusion for a lump sum calculated under current law depends on treaty interpretation and on the practice of the two administrations; it must be checked case by case and is not resolved by this factsheet. S11

5. Withholding tax, non-residents and anticipatory tax

25. Foreign workers without a settlement permit who are domiciled or staying in Switzerland are taxed at source on the income from their employment. Spouses living in a joint household are not subject to withholding tax if one of them has Swiss nationality or a settlement permit. The withholding is calculated on gross income and includes federal, cantonal and communal taxes. S03 S19

26. A subsequent ordinary assessment is mandatory where gross employment income reaches at least CHF 120,000 during the tax year, or where the taxpayer has income or wealth not subject to withholding tax. Other residents taxed at source may request one until 31 March of the following year. S06 S03 S19

27. Persons who are neither domiciled nor staying in Switzerland are taxed at source on certain Swiss-source income, in particular salaries from an activity carried on in the canton, the income of artists, sportspersons and lecturers, and the remuneration of members of the board or management of legal entities having their registered office or effective management in Switzerland. A non-resident may request a subsequent ordinary assessment if he or she is a quasi-resident, in particular where he or she generally declares in Switzerland at least 90% of his or her worldwide gross income, including that of his or her spouse. S03 S19 S06

28. Anticipatory tax (*impôt anticipé*) is a federal tax withheld at source on income from movable capital, certain gambling winnings and certain insurance benefits. Its rate is 35% for income from movable capital, 15% for life annuities and pensions, and 8% for other insurance benefits. The Federal Council may reduce the rate from 35% to 30% at the end of a year if the monetary situation or the capital market so requires. S07 S20

29. For a resident, anticipatory tax operates mainly as a security: a refund requires that the income, or the assets producing it, have been declared. A person who does not declare these items loses the right to a refund, subject to the exceptions provided for by law. Certain distributions, in particular of reserves from capital contributions, are not subject to anticipatory tax under the conditions of Article 5 LIA. S07 S20

30. For a non-resident, anticipatory tax is recoverable only to the extent provided for by a double taxation treaty or another agreement, by means of an application to the AFC. For a resident of France who is the beneficial owner of Swiss dividends, the treaty limits taxation in the source State to 15% of the gross amount, subject to the exemption regimes provided for certain company participations. The difference from the 35% withholding is a matter for a refund procedure, not an automatic reduction. S11 S20 S37

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Swiss-source income paid to a resident of France	Swiss domestic rule	Treaty limit (1966 treaty as amended)	Sources
Dividends, general case	Anticipatory tax of 35%	15% of the gross amount for the beneficial owner	S07 S11
Dividends between companies, participation of at least 10%	Anticipatory tax of 35%, notification procedure available in the cases provided for	Taxation in the State of residence only, subject to an anti-abuse clause	S11 S20
Royalties	No anticipatory tax on this income under the LIA	5% of the gross amount at most	S07 S11

6. Companies: tax liability, profit, rates and minimum taxation

31. Legal entities are liable to tax in Switzerland where their registered office or effective management is located there, and by reason of economic attachment in particular where they operate a permanent establishment or own immovable property there. Taxable profit starts from the commercial result, adjusted in accordance with the tax rules. Federal, cantonal and communal taxes are expenses justified by commercial use and are therefore deductible from taxable profit. S02 S21

32. The federal profit tax on capital companies and cooperatives is 8.5% of net profit. The cantons also levy a profit tax and a capital tax. According to the AFC, the majority of cantons apply a single proportional rate, while others, including Vaud, have a stepped scale. The effective cantonal rate also depends on the annual coefficient and communal multipliers; this factsheet does not reproduce any overall cantonal rate. S02 S21

33. A participation reduction applies for the IFD where the company holds at least 10% of the capital of another company, has a share of at least 10% in the profit and reserves, or holds rights with a market value of at least one million francs. The tax is reduced in proportion to the ratio between the net yield on participations and total net profit; the net yield takes into account financing costs and a 5% contribution to administrative costs. S02 S21

34. Since the Tax Reform and AHV Financing, the LHID has provided the cantons with a “patent box”: on application, profit from patents and comparable rights is taken into account according to the Nexus ratio with a 90% reduction, and the cantons may provide for a smaller reduction. The cantons may also allow an additional deduction of at most 50% of research and development expenditure incurred in Switzerland. The total reductions may not exceed 70% of taxable profit calculated in accordance with Article 25b LHID. S03 S21

35. In the event of liquidation or of the transfer abroad of the registered office, the management, a business or a permanent establishment, the hidden reserves built up out of untaxed profits are taxed together with the profit of the last financial year. The LIFD more broadly provides for the taxation of hidden reserves at the end of tax liability, including on the transfer of assets or functions to an establishment abroad. S02

36. Switzerland applies the OECD and G20 minimum taxation through the Ordinance of 22 December 2023, which entered into force on 1 January 2024. It covers multinational groups whose consolidated turnover reaches at least EUR 750 million and levies a top-up tax covering the difference between the effective rate and the 15% minimum rate. According to the AFC, the national top-up tax (QDMTT) has existed since 2024 and the international top-up tax under the IIR has applied since 1 January 2025. S10 S29 S21

37. The ordinance refers directly to the GloBE Model Rules for the international top-up tax and, by analogy, for the Swiss top-up tax, subject to certain exclusions, and contains provisions on the undertaxed profits rule (UTPR). Under its transitional provisions, the rules on the international top-up tax apply to tax years beginning on or after 1 January 2025, with the exception of Article 10, paragraph 3, relating to the UTPR, which “will apply at a later date”; the AFC page likewise mentions only the QDMTT and the IIR. The France–Switzerland treaty, as amended, specifies that it does not prevent the implementation of these domestic rules. S10 S29 S11

38. Federal stamp duties supplement the taxation of companies. The issue duty on participation rights is 1%, with an exemption for the first million francs of contributions under the statutory conditions, and the securities transfer duty on the transfer of securities by a securities dealer is 1.5 per mille for securities issued by a person domiciled in Switzerland and 3 per mille for those issued by a person domiciled abroad. S09 S22

7. VAT and stamp duties

39. Swiss VAT is a federal tax. The standard rate is 8.1%, the reduced rate 2.6% and the special rate for accommodation 3.8%, since the increase that entered into force on 1 January 2024 according to the AFC. The reduced rate covers, in particular, piped water, foodstuffs other than alcoholic beverages, medicines and certain printed matter; the special rate covers accommodation with breakfast, even if invoiced separately. S08 S28

40. The LTVA provides that the special rate for accommodation applies at the latest until 31 December 2027, subject to the extension of the constitutional time limit mentioned by the text. Any projection beyond that date therefore requires checking for a possible legislative amendment. The levying of VAT itself is limited by the Constitution to the end of 2035. S08 S01

41. Any person who operates a business and makes supplies in Swiss territory or has its registered office, domicile or a permanent establishment there is liable to VAT. A person whose total turnover in Switzerland and abroad from supplies not excluded from the scope of the tax is less than CHF 100,000 is exempt from liability. This threshold is assessed in the light of the conditions and exceptions of Article 10 LTVA, in particular for foreign businesses. S08 S30

42. VAT is not to be confused with stamp duties and real estate transfer taxes. Federal stamp duties, described in paragraph 38, apply to the issue of participation rights and to dealings in securities; real estate transfer taxes are cantonal or communal and are not levied in all cantons. A real estate or restructuring transaction must therefore be examined from these three distinct angles. S09 S22 S24

8. Real estate: imputed rental value, real estate gains and transfer taxes

43. An owner-occupier is currently taxed on the imputed rental value of the dwelling that he or she reserves for his or her own use, determined taking into account local conditions and actual use. Rents received are taxable as yield on immovable assets. The LHID also mentions the imputed rental value in the object of cantonal income tax. S02 S03

44. This taxation is set to disappear for the IFD: the version of the LIFD applicable on 1 January 2029 repeals letter b of Article 21, paragraph 1, and paragraph 2 relating to the imputed rental value, pursuant to the Federal Act of 20 December 2024 published in the Official Compilation 2026. The other adjustments made by this reform, in particular regarding deductions and cantonal law, have not been analysed in this factsheet. S13

45. Gains realised on the sale of immovable property forming part of private assets are not subject to the IFD, but are taxed in all cantons. Under the monistic system, applied according to the AFC by Zurich, Bern, Uri, Schwyz, Nidwalden, Basel-Stadt, Basel-Landschaft, Ticino and Jura, all real estate gains are subject to a special tax; under the dualistic system, in particular in Vaud, only gains on private assets are subject to it, business gains being subject to income or profit tax. Geneva has a particular rule: the special tax is levied on the transfer, and self-employed persons and legal entities also subject these gains to income or profit tax, the special tax being deductible from the latter. S16 S23 S03

46. The cantons generally provide for surcharges for a short holding period and reductions for a long holding period, according to their own scales. These parameters, like the rules on deferral of taxation in the event of reinvestment, are not harmonised in figures and must be read in the law of the canton in which the property is situated. S23 S03

47. Real estate transfer taxes apply to the transfer of immovable property; according to the AFC (November 2022), Schwyz levies neither a transfer tax nor a land registry fee, while Zurich, Uri, Glarus, Zug and Schaffhausen levy only a land registry fee. For a non-resident, ownership of Swiss immovable property also creates an economic attachment for the IFD and cantonal taxes, and the France–Switzerland treaty allocates to the State of situation the right to tax real estate income and gains. S24 S02 S11

9. Wealth: cantonal wealth tax and maximum tax burden

48. The Confederation does not levy a wealth tax on individuals; the cantons and communes do levy one. The tax is levied on total net wealth; assets subject to a usufruct are taxable in the hands of the usufructuary, and household furniture and personal effects in everyday use are not taxed. S03 S16 S18

49. Wealth is valued at market value, and the income value may be taken into account appropriately. Agricultural or forestry property is valued at its income value, and intangible assets and movable assets forming part of business assets at the value relevant for income tax. Scales, deductions and methods of valuing immovable property are a matter for cantonal law. S03 S18

50. For a resident taxed under the ordinary regime, wealth tax is added to income tax, without any federal ceiling. Some cantons do, however, provide for a maximum tax burden mechanism. In Geneva, for taxpayers domiciled in Switzerland, wealth and income taxes, including additional *centimes*, may not in total exceed 60% of taxable net income, the net yield on wealth then being set at not less than 1% of net wealth. This Geneva rule must not be transposed to other cantons. S33 S18

51. For a taxpayer taxed according to expenditure, the LHID leaves it to the cantons to determine how the lump-sum tax covers wealth tax. According to the AFC 2025 brochure, Geneva increases the amount used for income by 10%, while Vaud includes a 15% increase in the minimum amount of CHF 415,000. These examples show cantonal heterogeneity rather than a common rule. S03 S26

10. Cantonal inheritance and gift taxes

52. The Confederation does not levy any inheritance or gift tax. According to the AFC, all cantons except Obwalden and Schwyz levy an inheritance tax, and all except Lucerne, Obwalden and Schwyz a gift tax. The tax is generally levied on the shares of the estate; according to the AFC dossier on these taxes, only the canton of Solothurn taxes the estate as a whole, whereas the AFC 2025 brochure refers to “a few cantons”: the discrepancy calls for the law of the canton concerned to be checked. S27 S25

53. Apart from immovable property, which is taxed where it is situated, taxing jurisdiction belongs to the canton of the deceased’s last domicile or of the donor’s domicile. An heir domiciled in France does not therefore, on that basis alone, remove the jurisdiction of the deceased’s canton, and Swiss immovable property may be taxed in the canton in which it is situated even if the deceased was domiciled elsewhere. S27 S25

54. In many cantons, the spouse and descendants are exempt, but the rule varies. In Geneva, the Inheritance Duties Act exempts, in particular, the surviving spouse and relatives in the direct line; the exemption does not apply where the deceased benefited from taxation according to expenditure under one of the last three final assessment decisions. In that case, the AFC brochure reproduces progressive rates by bracket ranging from 2% to 6% for children and for fathers and mothers. In that case only, Article 5 LDS grants, on application by the heirs, a 50% reduction in the duties on the shares passing to statutory heirs of the first category (direct line and surviving spouse), if all the following conditions are met: the deceased and the person who was his or her spouse at the time of death were born outside Switzerland, have never held Swiss nationality, have never carried on a gainful activity in Switzerland, settled in the canton before 1 July 1979 and were domiciled there without interruption until death. This reduction does not apply to gifts inter vivos. S32 S27

55. In the canton of Vaud, the surviving spouse and the registered partner are exempt. For estates opened on or after 1 January 2025, each line of heirs (*souche*) of the first parentela benefits from an exempt amount of CHF 1,000,000, reduced by one hundredth for each thousand francs above that amount; the AFC also mentions the exemption of gifts in the descending direct line not exceeding CHF 300,000 per child and per calendar year, it being specified that above that amount the gift is taxable on the whole of the benefit: it is a threshold, not an allowance. Vaud rates vary according to the degree of kinship and the amount, and the communes of domicile may levy additional *centimes* up to the amount of the cantonal tax. S34 S27

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Inheritances: sourced cantonal reference points (2025 tax period unless stated)	Spouse	Descendants	Sources
Confederation	No federal tax	No federal tax	S27
Obwalden, Schwyz	No inheritance tax	No inheritance tax	S27
Geneva	Exempt, unless the deceased was taxed according to expenditure	Exempt, unless the deceased was taxed according to expenditure	S32 S27
Vaud	Exempt	Taxed above an exempt amount of CHF 1,000,000 per line of heirs, tapering, for estates opened from 2025	S34 S27

56. No treaty between France and Switzerland on inheritance taxes is in force at the date of this factsheet: the Fedlex metadata indicate that the treaty of 31 December 1953 has no longer been in force since 31 December 2014. Double Franco-Swiss taxation of an estate must therefore be analysed under domestic law and its unilateral credit mechanisms. S14

11. France–Switzerland treaty, cross-border workers and international obligations

57. The treaty of 9 September 1966, amended in particular by the amending protocols of 1997, 2009 and 2023, governs taxes on income and on wealth. In the event of dual residence of an individual, it applies successively the permanent home, understood as the centre of vital interests, habitual abode, nationality, and then agreement between the competent authorities. It does not allow residence to be chosen. S11

58. Salaries are in principle taxable in the State in which the employment is exercised, with the classic exception for stays not exceeding 183 days in the tax year where the employer is not a resident of the State in which the employment is exercised and the remuneration is not borne by a permanent establishment in that State. The treaty does, however, reserve the agreement of 11 April 1983 on cross-border workers, which forms an integral part of it. S11 S15

59. The 1983 agreement was concluded on behalf of the cantons of Bern, Solothurn, Basel-Stadt, Basel-Landschaft, Vaud, Valais, Neuchâtel and Jura. Under it, the remuneration of cross-border workers is taxable only in the State of residence, subject to financial compensation equal to 4.5% of the total annual gross remuneration. A cross-border worker is a person resident in one State who works in the other State for an employer established there and who, as a rule, returns each day to his or her State of residence. S15 S19

60. Geneva is not a party to the 1983 agreement. According to the AFC, cross-border workers working there are taxed at source according to the ordinary scales, and Geneva pays over to the French local authorities of Ain and Haute-Savoie 3.5% of the relevant payroll; France grants a tax credit equal to the French tax on that income. The other non-party cantons also levy withholding tax according to the ordinary scales. S19

61. The amending protocol (*avenant*) of 27 June 2023, in force since 24 July 2025, added a protocol on teleworking. Activities carried out by teleworking from the State of residence for an employer located in the other State are deemed to be carried out at that employer’s premises up to a limit of 40% of working time per calendar year; above that, the ordinary rules of Article 17 apply from the first day. The State that taxes that remuneration in principle pays the State of residence compensation of 40% of the taxes due on the teleworked portion. By way of derogation, for a resident of France employed in the canton of Geneva, that 40% compensation relates only to the fraction of teleworking between 15% and 40% of working time. The protocol also provides for an automatic exchange of information between the States for its application. S11

62. For a resident of France, double taxation is in principle eliminated by including the Swiss income in French tax and granting a tax credit. Depending on the category of income, this credit is equal either to the corresponding French tax or to the amount of tax paid in Switzerland up to the amount of the French tax. The exact nature of the credit depends on the applicable treaty article. S11

63. The treaty allocates to the State of situation the taxation of real estate income and real estate gains, including, subject to conditions, gains on shares or interests in companies whose assets consist principally of immovable property. It also provides for a mutual agreement procedure, which must be initiated within three years of the first notification of the action complained of, and a clause on the exchange of foreseeably relevant information. S11

64. International administrative assistance in tax matters is governed by the LAAF, and the automatic exchange of financial account information is based on the Council of Europe and OECD multilateral convention, the multilateral competent authority agreement and the agreement with the European Union. According to the AFC, the Swiss legal bases entered into force on 1 January 2017 and the first exchange took place in 2018. S12 S31

12. Illustrative cases and limits of application

65. First case: a French national without a gainful activity settles in Geneva and is considering lump-sum taxation. He or she must first establish a tax domicile, not have been subject to unlimited tax liability in Switzerland during the previous ten years and refrain from any gainful activity in Switzerland, conditions that his or her spouse must also meet. The 2026 IFD base may not be lower than CHF 435,000 or the other statutory minimums; the Geneva cantonal base follows the cantonal minimum and the increase for wealth. His or her status as a resident within the meaning of the France–Switzerland treaty and the Geneva inheritance regime must be examined separately. S02 S04 S26 S11 S32

66. Second case: an employee resident in Haute-Savoie works for a Geneva employer and teleworks two days a week. The employee’s salaries are subject to Geneva withholding tax, not to the 1983 agreement; the 2023 protocol allows the teleworking days to be attributed to the employer’s State up to a limit of 40% of annual working time. Two days out of five correspond exactly to 40%: the case lies at the limit, and additional teleworking days may be enough to exceed it. Exceeding this limit, in actual days, moves the allocation into the ordinary rules from the first day of teleworking. S11 S19

67. Third case: a resident of France holds 5% of a Swiss public limited company (*société anonyme*) that distributes a dividend. The company withholds 35% anticipatory tax; the shareholder may apply to the AFC for a refund of the portion exceeding the 15% treaty limit. In France, the dividend is included in the tax base in accordance with French law, with the credit provided for by the treaty. S07 S11 S20 S37

68. Fourth case: a Swiss subsidiary of a group whose consolidated turnover exceeds EUR 750 million benefits from the Vaud patent box or that of another canton. The cantonal reduction remains limited by Article 25b LHID, and the group must also check the Swiss effective rate against the QDMTT: a cantonal reduction may thus be offset, in whole or in part, by the Swiss top-up tax. S03 S10 S29

69. Limits: this factsheet does not present a complete scale for the 26 cantons, communal coefficients, church tax, social security contributions or sectoral regimes. The cantonal figures taken from the AFC brochures relate to 2025 and must be confirmed with the canton for 2026. The Geneva and Vaud examples are sourced illustrations, not a Swiss average. French law is mentioned only in order to situate the treaty rules. S16 S26 S27