On 13 May 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of railway personnel.
Remuneration paid to staff of SBB and civil servants who were previously employed by Deutsche Bundesbahn and who continue to be employed while retaining their civil servant status are not covered by Article 19 para. 4 DBA (staff working in border regions) if the activity is also carried out outside the border region. This generally applies to mobile railway staff employed in passenger and freight transport and in infrastructure maintenance (locomotive staff, train crew, locomotive drivers).
The full consultation agreement is available here.