The supplementary agreement to the double taxation agreement between Switzerland and France entered into force on July 24, 2025.

Its provisions, which permanently regulate the taxation of income from home offices, will apply from January 1, 2026.

In particular, it provides for income from home office to be taxed in the contracting state in which the employer is based up to an upper limit of 40% of working hours per calendar year and for the tax revenue to be transferred to the other state. An automatic exchange of information on wage data will ensure the application of the new rules.

In addition, the supplementary agreement updates other provisions, particularly in connection with the Base Erosion and Profit Shifting (BEPS) project.

Further information and the additional agreement DBA France are available here.