I live in Germany and work remotely for a Swiss company. Where do I pay taxes?

If you work fully from Germany, you are taxed in Germany. Days physically worked in Switzerland may be taxable in Switzerland; Swiss tax is creditable in Germany. Provide a German residency certificate. Hybrid work can affect commuter status (20% return/60 non-return days).

How do I prove my tax residency to apply the treaty?

Provide a tax residency certificate. In Switzerland: from your cantonal tax administration (with FTA seal). In Germany: Ansässigkeitsbescheinigung from your Finanzamt. Submit to the payer or with your refund/relief application.

What if tax was withheld at full rates in both countries?

File for credit/refund using proof of tax paid and your residency certificate. In Germany, claim foreign tax credit; in Switzerland, apply via the ESTV ePortal. If unresolved, request a Mutual Agreement Procedure (MAP).

Does the treaty cover inheritance and gift taxes?

No. Inheritance and gift taxes are outside the DTA. Switzerland: cantonal taxes vary. Germany: 7%–50% with allowances by relationship. Assets must be declared in both countries.

Can I claim treaty benefits if I have dual residency?

Yes, based on tie-breaker rules: permanent home, center of vital interests, habitual abode, then nationality. Once determined, claim benefits as a resident of that state.

Are there any anti-avoidance provisions in the treaty?

Yes. The Principal Purpose Test (PPT) can deny treaty benefits if one principal purpose of an arrangement is to obtain those benefits. Genuine substance and business purpose are required.

17.12.2025

Switzerland-Germany double taxation agreement: complete guide

The Agreement between the Swiss Confederation and the Federal Republic of Germany for the Avoidance of Double Taxation with respect to Taxes on Income and Capital is a bilateral treaty designed to prevent the same income and capital from being taxed twice—once in Switzerland and again in Germany—by allocating taxing rights between the two countries and providing mechanisms for relief.

Taxes in Switzerland

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