Switzerland, France Sign MoU on MAP Concerning Cross-Border Workers Under Fifth Protocol to 1966 DTA

The Swiss Federal Tax Administration May 1 announced the April 29 signing of a memorandum of understanding (MoU) with France for mutual agreement procedures (MAP) concerning the taxation of cross-border teleworking, based on the fifth protocol to the 1966 DTA between the countries, which was signed June 27, 2023, and entered into force July 24, 2025. The MoU includes measures clarifying that: 1) telework carried out from the country of residence only includes temporary assignments that an employee carries out there or in a non-EU country for their employer; 2) the length of the temporary assignment must comply with both ...