Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
Note: This language version is an automatically generated translation. The text may therefore contain linguistic and terminological errors.
view in original language (German)Julia Müller is employed by the international corporation N AG. In 2023, she worked for the German subsidiary in Stuttgart (Germany). Since January 1, 2024, she has been employed by the Swiss sister company based in the city of Bern. Her gross salary is CHF 500,000. In addition, she will receive a bonus of CHF 50,000 in June 2024 for her work at the German subsidiary. Ms. Müller is not an executive.
Ms. Müller lives in Germany with her husband and their child in a single-family home in Grenzach-Wyhlen. Generally, Ms. Müller returns to her residence, located approximately 100 km away, every day after work. Every other Friday, she works from her home office in Grenzach-Wyhlen (24 days per year). Furthermore, in 2024, she will be unable to return to her place of residence on 70 days for professional reasons. The days she does not return are worked in Switzerland.
Mrs. Müller’s husband works for the German company V AG, which has offices in Villingen-Schwenningen (Germany). He earns a gross salary equivalent to CHF 50,000. The family does not belong to any national church.
In addition to their earned income, the Müllers will earn CHF 10,000 in investment income in 2024. The imputed rental value (calculated according to Swiss tax law) for the house in Grenzach-Wyhlen is CHF 25,000.
In 2024, Mrs. Müller made a 2nd pillar purchase of CHF 50,000 and paid a 3a pillar contribution of CHF 7,000. Her transportation costs amounted to CHF 20,000 and third-party childcare costs to CHF 10,000.
Ms. Müller lives with her family in Paris (France) and returns to her French residence only on weekends. During the week, she lives in a two-bedroom apartment in the city of Bern. Due to the nature of her work, she is unable to work from home. The rent amounts to CHF 10,000 per year. For the remaining facts, please refer to the basic facts. How is Ms. Müller taxed in Switzerland, and are the requirements for a subsequent ordinary assessment met?
Ms. Smith is hired locally by a company in Zurich as of January 1, 2025. Ms. Smith’s family remains resident in London, and she returns to her family regularly. Based on the number of days spent in the UK, Ms. Smith does not qualify as a resident there. Ms. Smith travels frequently for work and spends approximately 130 working days outside the UK or Switzerland. In Switzerland, Ms. Smith rents an apartment in Zug.
Tim Bieri is a Swiss citizen residing in Munich (Germany). He lives in Munich with his husband and their two children. Mr. Bieri is the managing director of IT AG, headquartered in the city of St. Gallen, and earned a gross annual salary of CHF 300,000 in 2025. Mr. Bieri works three days a week at the IT AG offices in St. Gallen and the remaining two days from his home office in Munich. He spends the nights from Monday to Tuesday and from Tuesday to Wednesday at a hotel in St. Gallen.
Under which procedure is taxation carried out in Switzerland?
For which income does Switzerland have the right of taxation?
Eva Schmid lives in Berlin (Germany) with her partner and her son from a previous relationship. She works in marketing for an international company in the healthcare sector based in Basel. She works from her home office in Germany every other week. For the weeks she works in Basel, her employer provides her with company housing. Her gross annual salary for the 2024 tax year is CHF 150,000.
The relevant German tax office taxes the workdays performed in Germany during the 2024 tax year. This results in international double taxation regarding the workdays not performed in Switzerland in 2024. Immediately after receiving the German tax assessment in May 2025, Ms. Schmid contacts the tax administration of the Canton of Basel-Stadt and applies for a refund of the withholding taxes levied in Switzerland in the amount of the double taxation. She is also bothered by the fact that she pays taxes in two countries and must subsequently claim a refund. For liquidity reasons, she would like to pay only the tax owed directly in both countries.
Mr. Meier resides with his family in Singen (DE). Mr. Meier signs an employment contract with a Zurich-based company and begins work on January 1, 2024. Due to his role, Mr. Meier travels frequently (a total of 50 travel days per year). Additionally, Mr. Meier works from home in Germany for 4 days per month (48 days per year).
In April of the following year, the Müller family moves from Singen to Freiburg im Breisgau (152 kilometers each way) for personal reasons.
Ms. Koller lives with her family in France. On January 1, 2024, she starts a job at a company in Basel. She returns to her family home in France every evening (the distance between her home and workplace is 90 kilometers each way). It is agreed that Ms. Koller will work from home one day per week (48 working days per year). In addition, Ms. Koller takes 10 business trips per year (5 days in France and 5 days in third countries). She is also required to be on call for 40 days and therefore does not return to her residence in the evening.
Ms. Koller would like to spend more time with her family, and in consultation with HR, the number of work-from-home days will be increased to a total of 120 days per year starting the following year. Additionally, Ms. Koller continues to have 10 business trips per year and must be on call for 40 days.
