Withholding tax at source and cross-border workers

Read the PDF edition (2 pages)

Geneva’s tax system has a peculiarity linked to the canton’s geography: a significant proportion of the people who work there reside in France. These cross-border workers are taxed at source in Geneva, the canton passing on to the neighbouring French départements a financial compensation calculated on the payroll, under an agreement concluded in 1973.¹ This mechanism, unique in Switzerland, illustrates the economic integration of the Franco-Vaud-Geneva region and the cross-border arrangements that Part C mentioned in connection with the free zones.

The financial centre employs many cross-border workers, in banks, trading companies and service providers. Their tax position, their social security cover and the conditions of their mobility depend on the agreements between Switzerland and the European Union, and in particular on the Agreement on the Free Movement of Persons. Debates on remote working by cross-border workers, on the allocation of tax revenue and on relations with the European Union therefore bear directly on the financial centre.²

For foreign executives employed by Geneva institutions, taxation at source also applies, under certain conditions, with the possibility of subsequent ordinary assessment. Institutions that recruit internationally must master these rules, which influence the centre’s attractiveness to talent.

Notes

Franco-Swiss agreement of 29 January 1973 on financial compensation in respect of cross-border workers employed in Geneva: 3.5% of the gross payroll of cross-border workers from the Ain and Haute-Savoie; Comité régional franco-genevois, “La compensation financière genevoise”, crfginfo.org (accessed September 2026). ↩
Transitional agreement of 22 December 2022 and protocol amending the Franco-Swiss tax treaty signed on 27 June 2023, allowing up to 40% of working time to be spent in remote working; Ministère de l’Économie (France), economie.gouv.fr (accessed September 2026). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

English

Contact

Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

Get in touch →

Withholding tax at source and cross-border workers

Notes

Setting up or expanding in Switzerland?