Taxation of international executives
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.
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.
What income will be taxed during short-term assignments?
Salary and other standard compensation not exempted by a double tax treaty.
© 2018 KPMG Holding AG is a member of the KPMG network of independent firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss legal entity.
KPMG International Cooperative (“KPMG International”) is 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.