On 25 June 2024, Switzerland’s tax authorities published “Federal Decree No. 1461/2024 of 14 June 2024” in the Official Gazette. This decree sets a referendum deadline of 3 October 2024 for the approval of the Additional Agreement, signed on 27 June 2023, to the 1966 France-Switzerland Income and Capital Tax Treaty.
The Additional Agreement addresses the taxation of cross-border teleworkers and provides clarification for preventing double taxation in this increasingly prevalent work arrangement.
The agreement must be ratified by the Swiss Federal Council (Bundesrat), which is expected to take place after the referendum deadline.
The French Council of Ministers had already approved the pending protocol with Switzerland, amending the 1966 income and capital tax treaty on 26 June, 2024. The Swiss Council of States announced that it ratified the pending protocol to the income and capital tax treaty with France on 30 May, 2024.
The agreement, which is the fifth amendment to the treaty, was first signed on 27 June 2023. It will become effective on 1 January of the year following its enactment.
Earlier, the tax treaty was amended by protocols in 1969, 1997, 2009, and 2014.
