Expatriation to Switzerland involves more than just a change of residence: it also entails a complete review of the tax situation, income and assets held. In the event of an ill-prepared departure, each category of investment or remuneration may trigger specific tax obligations in France, Switzerland, or both. Careful anticipation is essential to control flows, avoid conflicts of residence and manage the consequences of a departure on existing wealth structures. Income to watch before you leave Stock options and free shares Deferred profit-sharing schemes (bonus shares, stock options) call for particular attention in the event of mobility. When part of the vesting or exercise period takes place in France, the tax authorities may consider that a portion of the capital gain remains taxable in France. The applicable regime depends on whether the gain is professional or not, the exercise date and the nature of the plan. A chronological breakdown of rights and detailed documentation are necessary to avoid any double taxation. Cryptoassets and digital assets Cryptocurrency portfolios should be examined prior to any change of residence. Transfers made before departure are subject to the French system (flat tax or scale), while after departure, Swiss rules apply depending on the status of the holder and the canton. An arbitration on the time of sale can be carried out to secure the applicable tax regime and prevent gains from being reclassified as professional income at a later date. Employee savings and profit-sharing Employee savings products (PEE, PERCO) benefit from a favorable framework

Tax aspects of moving to Switzerland Exit tax and immediate consequences Taxpayers leaving France for Switzerland may be subject to exit tax. This measure is aimed at individuals transferring their tax domicile outside France, while holding significant movable assets. It applies in particular to unrealized capital gains on financial securities held at the time of departure. A deferral of taxation can be requested under certain conditions, and an exemption is possible if the securities are not sold within five years. To avoid any difficulties with the authorities, it is essential to anticipate these consequences right from the start of the process. Cantonal specificities and lump-sum taxation Switzerland has a decentralized tax system, with each canton applying its own rules. Some cantons offer an advantageous system for wealthy individuals, known as forfait fiscal. This mechanism allows taxation on the basis of lifestyle rather than actual income, subject to eligibility conditions. Arbitrating between cantons is therefore a strategic step. It is advisable to compare plans before departure, to structure an optimized installation. Teleworking and cross-border taxation Telecommuting between France and Switzerland raises specific tax issues. A bilateral agreement authorizes up to 40% teleworking in France, without jeopardizing frontier worker status. Beyond that, taxation in France becomes a possibility. Employers must also ensure that they comply with registration requirements. It is therefore essential to understand the tax obligations of expatriates and non-residents to ensure the security of this hybrid working arrangement. Tax residency criteria Determining your tax residence is the first step in

Understanding the tax rules between France and Switzerland helps to limit tax overlaps and ensure tax compliance. Bilateral treaties provide a framework for taxing rights between the two countries, enabling income and investments to be organized within a clear regulatory framework. For taxpayers with interests in both countries, the analysis of tax residency, reporting obligations and mechanisms for eliminating double taxation is a structuring step. Tax agreements between France and Switzerland: application framework The Franco-Swiss tax treaty divides the right to tax according to the nature of the income (salaries, pensions, dividends, interest, capital gains) and the place of residence. The treaty applies to all individuals and legal entities with tax links with both countries. In particular, it defines the tax residence in the event of a double connection, identifies the income concerned and specifies the competent country for taxation purposes. Before moving to, expatriating from or returning to France, you need to clarify your tax situation. Tax credits and neutralization of double taxation When income is taxable in both countries, corrective mechanisms apply. In France, tax already paid abroad can be offset against French tax by means of a tax credit. This credit is equivalent to the foreign tax or capped at the French tax, depending on the income category. Applying the right mechanism requires precise knowledge of the source of the income and the elimination rules laid down in the treaty. Social contributions, levies and asset flows Social security rules can lead to double affiliation if not properly

Investing in digital assets involves specific tax obligations, all the more so when it takes place in a cross-border context between France and Switzerland. Cantonal tax regimes, declaration of accounts, capital gains, decentralized financial operations: the applicable tax regime depends on both the type of operation and the place of tax residence. This guide sets out the current rules and practices to be followed. Regulations and tax framework for cryptoassets The taxation of cryptoassets is based on a legal qualification that varies from country to country. In Switzerland, FINMA considers them to be assets, which it classifies as payment, investment or utility tokens. This classification determines tax treatment. Each canton retains a margin of discretion, which leads to differences in concepts such as taxable assets and private investor status. Although the MiCA regulation is not applicable in Switzerland, it does influence trade with the European Union. The traceability, transparency and investor protection obligations it introduces can have an impact on cross-border transactions. Tax residency determines the rules governing tax returns. French residents must declare their foreign platform accounts and capital gains. In Switzerland, tax rules differ from canton to canton. Before embarking on any investment strategy, it is therefore essential to identify your precise residence and the applicable tax regime. Typology of operations and associated tax regime Crypto transactions are subject to different tax rules depending on their nature: Trading and capital gains: exempt in Switzerland for private investors meeting certain criteria, subject to a flat tax of 30% in

Wealth taxation differs significantly between France and Switzerland. While France concentrates its taxation on real estate via the IFI, Switzerland retains a tax on all assets, with rates varying from canton to canton. For taxpayers with assets in both countries, it is essential to understand the applicable rules, valuation methods, reporting obligations and the effects of tax treaties. This knowledge enables them to structure their assets in compliance with regulations. French and Swiss tax regimes: logic, basis and territoriality In France, the abolition of the ISF in favor of the IFI has refocused taxation on real estate assets alone, whether held directly or via companies. Financial investments are excluded from the tax base. Switzerland, on the other hand, continues to tax wealth at cantonal and municipal level, including all assets, whether real estate, accounts, securities or valuables. Thresholds and rates vary considerably from canton to canton. Tax residence determines the scope of taxation. A French resident declares all his worldwide real estate assets for IFI tax purposes, while a Swiss resident is subject to cantonal rules on all his assets. In the case of assets located in the other country, tax treaties regulate the respective taxation rights. Valuation and base exclusions Tax is calculated on the basis of the net taxable value, after deduction of justifiable debts. In France, only property-related debts are allowed. In Switzerland, personal debts can be deducted, but conditions vary from canton to canton. Certain assets benefit from special treatment. Life insurance policies, for example, can

Residing or doing business between France and Switzerland raises complex tax issues. Differences in tax systems, residency rules, taxation of income and assets, double taxation mechanisms and declaratory procedures require a thorough understanding of the tax laws of both countries. If this is not done in advance, there is a high risk of declaratory errors or tax reassessments. BERGEOT PAOLI Associés assists its clients in analyzing these cross-border situations, with a strategy adapted to each profile. Overview of the French and Swiss tax systems The French tax system is based on a progressive income tax, applied to all the income of the tax household. Tax is levied on all the worldwide income of a tax resident, including salaries, dividends, capital gains, pensions and property income. Added to this is the real estate wealth tax (IFI) and various social security contributions. Switzerland takes a very different approach: taxation is decentralized, with rates varying according to canton and commune of residence. Wealth tax is more widely applied than in France, but income tax can be more favorable, particularly for high-income taxpayers. This decentralization creates significant differences in tax pressure for the same income. Tax residence as the pivot of taxation The notion of tax residence is decisive. Under French law, residence is defined as the place of domicile, the center of economic interests and the place where the main activity is carried out. Switzerland, on the other hand, considers a person to be resident if he or she stays for more than

Tax residency determines in which country you are taxed on your income, assets or pensions. Between France and Switzerland, the assessment criteria differ and can lead to situations of dual residence. A rigorous analysis will help you to secure your status and avoid any errors in declarations or tax reassessments. This issue lies at the heart of personal taxation, with concrete implications for working people, retirees and cross-border commuters. Criteria for determining tax residence Before settling or working on either side of the border, it’s essential to understand how the French and Swiss administrations define tax residence. Each country applies its own criteria, and bilateral agreements help to resolve any qualification conflicts. These rules apply equally to working and retired people, expatriates and cross-border commuters. Criteria for tax residence in France France considers a tax resident to be anyone whose home or main place of residence is in France, who carries out his or her main professional activity in France, or who has his or her center of economic interests in France. These criteria are cumulative and make it possible to establish residency in the event of a dispute. Criteria for tax residence in Switzerland In Switzerland, a person is considered a tax resident if he or she stays in the country for more than 30 days with gainful employment or more than 90 days without employment. Entry in the register of residents and center of economic interests are also decisive. Differences between tax domicile and civil domicile The tax