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Switzerland - Special considerations for short-term assignments

Switzerland - Special considerations for short-te...

Taxation of international executives

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Residency rules

Payroll considerations

Taxable income

For the purposes of this publication, a short-term assignment is defined as an assignment that lasts for less than one year.

Residency rules

Are there special residency considerations for short-term assignments?

Assignees coming from a country with a double taxation treaty with Switzerland will generally be subject to the provisions of Article 15 of the double tax treaty (such as, 183 days test).

If assignees come from a country which has no double taxation treaty with Switzerland, these individuals are normally taxable from their first day in Switzerland - and there is no unilateral relief from double taxation.

Payroll considerations

Are there special payroll considerations for short-term assignments?

Unless exempted under Article 15 of the double tax treaty, the Swiss entity to which the employee is assigned is required to withholding tax for all L and B permit holders. Income paid out in the home location will need to be shadowed in the Swiss entity. If an exemption under the double tax treaty is available, the exemption from withholding tax generally needs to be requested with the tax authorities.

Taxable income

What income will be taxed during short-term assignments?

Salary and other standard compensation not exempted by a double tax treaty.

Disclaimer

All information contained in this publication is summarized by the Global Mobility Services department of KPMG AG, affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity, based on the Swiss Income Tax Code of 14 December 1990 and subsequent amendments and corresponding commentary; the Website of the Swiss federal tax administrations; the Swiss Social Security Act of 20 December 1946 and subsequent amendments; the Website of the Swiss Social Security administration (BSV); OECD model tax convention and corresponding commentary; and the various cantonal tax administrations.

Copyright

© 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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