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France: Memorandum of understanding on cross-border work under Swiss income tax treaty

Defining conditions under which cross-border telework remain taxable in the employment state

June 18, 2026

The French and Swiss competent authorities (CAs) on April 29, 2026, concluded a memorandum of understanding under the France-Switzerland income tax treaty, defining conditions under which cross-border telework (up to 10 days and 40% of annual working time) remain taxable in the employment state.

The memorandum outlines calculation methods, prioritization rules for workdays, and proportional adjustments for part-year or part-time employment.


For more information, contact a KPMG tax professional in France:

Marie-Pierre Hôo | mhoo@kpmgavocats.fr

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