What is cross-border teleworking?
Cross-border telecommuting concerns workers resident in one country (e.g. France or Italy) but employed in another (e.g. Switzerland). This mode of working raises complex issues relating to taxation and social security, as the activity is carried out in two different jurisdictions. To avoid double taxation and simplify administrative procedures, bilateral agreements between Switzerland and its neighbors have been put in place.
Since 2020, telecommuting has transformed working practices. Cross-border commuters, particularly those working in Switzerland but residing in France or Italy, benefit from specific agreements that guarantee fiscal and social stability. In 2025, these agreements remain in force, offering greater flexibility while maintaining clear rules to avoid administrative complications.
The advantages of cross-border teleworking
Telecommuting offers numerous advantages for employers and employees alike:
- Reduced costs: Lower transport and infrastructure costs for employers.
- Greater flexibility: Employees can better reconcile their professional and personal lives.
- Improved productivity: The right work environment can boost performance.
- Attractiveness for talent: Swiss companies can recruit cross-border commuters without undue constraints.
However, challenges remain, particularly in terms of communication, collaboration and productivity management. That’s why a clear contractual framework, such as a teleworking agreement, is essential.
Fiscal framework for cross-border teleworking in 2025
Franco-Swiss agreement: continuity until December 31, 2025
Switzerland and France have extended their amicable agreement on cross-border teleworking until December 31, 2025. This agreement, which is still in force, allows cross-border workers to telework up to 40% of their working hours without any tax impact. This means that their entire salary remains taxable in Switzerland, as if they were working locally, thus avoiding double taxation.
Details of the agreement
- 40% threshold: Cross-border commuters can telework up to 40% of their annual time (including temporary assignments, such as business trips, limited to 10 days per year).
- Taxation in Switzerland: As long as this threshold is respected, Switzerland retains the right to tax the entire salary via withholding tax.
- Temporary assignments: Business or training trips to France or a third country are included in the 40% calculation, up to a maximum of 10 days per year.
What happens if the threshold is exceeded?
If the 40% threshold is exceeded :
- All teleworking days are taxable in France from the first day.
- Temporary assignments exceeding 10 days are also taxed in France, with a distinction:
- Assignments in France: Taxed via the French withholding tax, which may pose a problem under Article 271 of the Swiss Penal Code.
- Missions in a third country: Taxed in France, but the tax is payable directly by the employee.
To avoid these complications, employers need to precisely document the rate of teleworking and temporary assignments via a contract or agreement.
Switzerland-Italy agreement: a specific regime
As of January 1, 2024, Switzerland and Italy have introduced a sustainable tax regime for cross-border commuters:
- 25% threshold: cross-border commuters can telework up to 25% of their working time without any tax consequences. Their salary remains taxable in Switzerland via withholding tax.
- Definition of a cross-border commuter: Residing in a commune less than 20 km from the border, returning home daily (with a tolerance of 45 days per year), and working in a border region (Grisons, Ticino, Valais for Switzerland; Lombardy, Piedmont, Aosta Valley, Bolzano for Italy).
Other EU/EFTA countries
For employees living in other EU/EFTA countries that have signed the framework agreement (such as Germany, Austria or Belgium), teleworking is possible up to 49.9%, with no social security implications. For tax aspects, please refer to specific bilateral agreements. For non-signatory countries, the threshold is 24.9%.
Social security and cross-border teleworking
Since July 1, 2023, a new framework agreement has enabled cross-border workers from certain EU/EFTA countries (Germany, Austria, Belgium, France, Italy, etc.) to telework up to 49.9% of their time without impacting their social security liability. They remain affiliated to the social security system of their employer’s country of residence (Switzerland).
For non-signatory countries, the threshold is 24.9%. Above this threshold, workers are subject to the social security system of their country of residence for the entire duration of their employment.
Employer obligations in 2025
Employers must :
- Document telework: Provide a contractual document (employment contract or telework agreement) attesting to the percentage of telework granted.
- Prepare the transition for 2026: With the planned entry into force of the Franco-Swiss agreement, employers will be required to transmit teleworking data to the Federal Tax Administration (AFC) from January 2027 for the 2026 tax year.
- Update systems: Use version 5.0 of ELM Swissdec software to transmit tax data, or prepare to use ISEL channels or paper attestations.
Tips for employers and employees
For employers
- Draw up a telecommuting agreement: employers can use the model proposed by FER Genève to provide a framework for the practice of telecommuting.
- Follow the thresholds: employers must respect the limits of 40% (France) or 25% (Italy) to avoid tax complications.
- Consult the experts: employers can refer to the OFAS and DFF guides, or to the “Cross-border teleworking guide” for detailed recommendations.
For employees
- Check your status: Make sure you meet the teleworking thresholds to avoid being taxed in France or another country.
- Ask for a clear agreement: An applicable written agreement with your employer guarantees transparency on your tax and social obligations.
- Get the facts: Consult official resources, such as the OFAS or DFF websites, to understand your rights.
Useful resources
- FSIO: Information on social security and teleworking.
- FDF: Details of Franco-Swiss and Swiss-Italian tax agreements.
- FER Genève: Model telework agreement and practical guide.
- Cross-border teleworking guide : Comprehensive document drawn up by the economic organizations of French-speaking Switzerland.
Conclusion
In 2025, cross-border telecommuting remains a flexible and advantageous solution for employers and cross-border workers, thanks to well-defined bilateral agreements between states. For others, the opposite solution – moving directly to Switzerland – may offer a more stable living environment, despite higher costs, especially if you plan to settle in Geneva’s upmarket districts.
Whether your place of residence is in France, Italy or another EU/EFTA country, it’s crucial to understand the tax and social security thresholds to avoid any complications. By adopting a clear teleworking agreement and complying with legal obligations, employers and employees can take full advantage of this practice while remaining compliant with regulations.
For more information or personalized support, consult official resources or join a community of experts to master your border status depending on where you live.
