Senior Executives In Cross-Border Relations Between Switzerland And Germany

In the context of cross-border employment relationships between Germany and Switzerland, also the question of the allocation of taxation rights for employment income of employees in management positions arises. The following article examines the tax classification and specific Swiss tax practice for senior executives who are tax residents in Germany and hold a senior position at a company based in Switzerland.

Swiss tax law

Individuals who are not tax resident in Switzerland are subject to limited tax liability in Switzerland if, among other things, they physically carry out gainful employment in Switzerland or if they physically carry out gainful employment abroad for an employer with its registered office, actual administration or permanent establishment in Switzerland and Switzerland is granted the right of taxation with regard to the gainful employment physically exercised abroad in accordance with the applicable double taxation agreement with the respective