Tobias Stiegler

The intra-group deployment of specialized personnel between Switzerland and Germany raises complex tax and social security issues. Drawing on a comprehensive real-world example, this article analyzes six typical scenarios—ranging from a simple service contract to a CEO working from home in the border region. It examines the implications of recent legal changes: the new domestic legal basis for senior executives (Art. 5(1)(a bis) DBG), the revised double taxation treaty between Switzerland and Germany, and the 2025 OECD Model Commentary on the home office as a permanent establishment.