Where Do Cross-Border Workers Pay Income Tax?
General information — France / Switzerland
General Principle
Where cross-border workers are taxed depends on several factors:
- Country of residence
- Canton of employment
- Bilateral agreements between France and Switzerland
Two Main Frameworks
Taxed in Switzerland (Withholding at Source)
Your employer withholds Swiss source tax (Geneva, Fribourg, Zurich, Ticino and the other cantons outside the eight of the 1983 agreement — France–Switzerland convention of 9 September 1966; 2047-SUISSE notice, CAS 2 « including the canton of Geneva »).
The salary is also declared in France on the 2047-SUISSE annex (CAS 2.A): carried to lines 1AF to 1DF and 8TK of the 2042 return, it gives a tax credit equal to the French tax, on proof of the Swiss tax (2047-SUISSE notice).
Quasi-residence: if at least 90% of your household's worldwide gross income (you and your spouse) is taxable in Switzerland, you may request an ordinary taxation (TOU) from the tax office of your canton of work, in writing, by 31 March of the following year, every year; once filed, the request cannot be withdrawn (LIFD art. 99a; OIS art. 14).
Taxed in France (Specific Cantons)
Your pay is taxable in France, your state of residence, under the France–Switzerland agreement of 11 April 1983 (art. 1) — not the 1966 tax convention — provided you return home to France as a rule every day: at most 45 nights in Switzerland a year for full-time work (2047-SUISSE notice) — at most one a week, and part time in proportion to the activity rate (ne.ch); agreement, art. 3.
Give your Swiss employer the tax-residence certificate 2041-AS, stamped by your French tax office (then the 2041-ASK that renews it), before your first working day and then every 1 January; otherwise the employer withholds Swiss source tax (ne.ch).
Declare the salary in France on the 2047-SUISSE annex, box « CAS 1 »: net salary on lines 1AG to 1DG of the 2042 return, and lines 8TJ/8TY (2047-SUISSE notice).
The eight cantons of the agreement: Bern, Solothurn, Basel-Stadt, Basel-Landschaft, Vaud, Valais, Neuchâtel, Jura. In return, France (the state of residence) pays these cantons a financial compensation (agreement, art. 2).
Canton-by-Canton Reference
The table below indicates, for each canton, the country where income tax is generally levied for cross-border workers residing in France. These rules stem from the Franco-Swiss tax convention of 9 September 1966 (general framework) and the accord of 11 April 1983 on the taxation of cross-border workers (cantons taxed in France).
| Canton | Place of Taxation |
|---|---|
| Geneva (GE) | Switzerland (withheld at source) |
| Vaud (VD) | France |
| Valais (VS) | France |
| Neuchâtel (NE) | France |
| Jura (JU) | France |
| Berne (BE) | France |
| Basel-Stadt (BS) | France |
| Basel-Landschaft (BL) | France |
| Soleure (SO) / Solothurn | France |
| Zurich (ZH) | Switzerland (withheld at source) |
| Aargau (AG) | Switzerland (withheld at source) |
| Lucerne (LU) | Switzerland (withheld at source) |
| St. Gallen (SG) | Switzerland (withheld at source) |
| Thurgau (TG) | Switzerland (withheld at source) |
| Ticino (TI) | Switzerland (withheld at source) |
| Fribourg (FR) | Switzerland (withheld at source) |
| Schaffhausen (SH) | Switzerland (withheld at source) |
| Other cantons | Switzerland (withheld at source) |
Sources: Franco-Swiss tax convention of 9 September 1966, as amended (cantons taxing at source); Franco-Swiss agreement of 11 April 1983 (the eight cantons taxed in France, listed in its preamble); notice of the 2047-SUISSE annex (impots.gouv.fr).
Why It Differs
Bilateral tax treaties between France and Switzerland define the allocation of taxation rights between the two states. These agreements determine which country has the right to levy income tax based on the canton of employment and the worker’s place of residence.
Tax rules depend on bilateral agreements and individual circumstances.
AdminLanding does not provide tax advice.
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