The France-Switzerland tax treaty, point by point

The convention between France and Switzerland on taxes on income and capital was signed in Paris on September 9, 1966. Five acts have amended or supplemented it: the amendments of December 3, 1969, July 22, 1997, and August 27, 2009; the agreement of June 25, 2014, on the additional protocol; and the amendment of June 27, 2023, which entered into force on July 24, 2025. The convention on successions of December 31, 1953, ceased to have effect on January 1, 2015: do not cite it as a rule in force.

A text from 1966 and its amendments

The French administration publishes a consolidated version of the convention of 9 September 1966 and its additional protocol, as amended by the addenda of 3 December 1969, 22 July 1997 and 27 August 2009. This consolidated text predates two acts which are mentioned on the official France-Switzerland texts page (impots.gouv.fr/suisse) and the administrative list of conventions (BOI-ANNX-000306, version of 29 April 2026):

• the agreement of 25 June 2014, which amends the additional protocol (point XI, exchange of information on request, in connection with article 28); ;
• The amendment of 27 June 2023, in force since 24 July 2025 (Official Journal of 23 August 2025). It adds in particular to Article 17 a paragraph 5 on teleworking, an Article 28 ter (annual automatic exchange of information), an Article 29 bis (main purpose clause) and a point XIII of the protocol (minimum tax, pillar two).

The rules summarized below reproduce the consolidated text; the 2023 amendment is superimposed on it for the articles it modifies.

The third amendment came into effect on November 4, 2010 and applies to income from January 1, 2011.

Switzerland is not included in the administrative list of conventions modified by the multilateral convention (MLI): BOI-ANNX-000511, of 29 April 2026. The list does not give the reason.

Income-based rules

The taxes in question

On the French side, the convention covers income tax, corporate tax, payroll tax, and wealth tax. On the Swiss side, it covers federal, cantonal, and municipal taxes.

The text mentions the ISF; its application to the IFI is examined on a case-by-case basis.

Who is a resident?

Article 4 § 1 defines a resident of a State as: a person liable to tax in that State by reason of his domicile, residence, place of management or a similar criterion.

If you are a resident of both countries, Article 4, paragraph 2, prioritizes your permanent home: you are considered a resident of the country where you have such a home. The following criteria are listed in the text, in the order it specifies. French tax domicile is a separate concept, addressed on our page about leaving France. The situation of individuals taxed in Switzerland on a lump-sum basis is not covered here.

Dividends and Swiss withholding tax

Dividends. Article 11, paragraph 2(a), allows the source state to tax up to 15 % of the gross amount. Paragraph 2(b) reserves taxation to the recipient state for certain companies that hold at least 10 % of the capital; its full conditions are set out in the text.

One point not to be confused. According to the Swiss Federal Tax Administration (as of January 1, 2024), Switzerland levies an withholding tax of 35 % on dividends and interest from Swiss debtors. For a person domiciled abroad, this tax is generally final, unless a refund is provided for by a tax treaty, and the refundable percentage depends on the treaty. The refundable portion under the Franco-Swiss tax treaty is not specified here; therefore, the 15 % ceiling in Article 11 does not, on its own, indicate what you will actually pay in practice.

Capital gains

For capital gains on real estate, Article 15 stipulates the state where the property is located. For capital gains on other assets, it generally provides for taxation only in the state of which the transferor is resident. The other paragraphs of the article set out specific rules, for example, for the assets of a permanent establishment. Only the general rule is presented here.

Wages and the 183-day rule

Article 17 § 1 refers to the State of residence: the salaries of a resident are taxable only in that State, unless the employment is carried out in the other State.

Paragraph 2 provides an exception based on duration: the stay in the other State must not exceed 183 days in total during the tax year. Other conditions apply, particularly regarding the employer and the permanent establishment that would bear the cost. The full text of the article should be examined.

Teleworking. The amendment of June 27, 2023, in force since July 24, 2025, adds paragraph 5 to Article 17. It applies notwithstanding paragraph 1, but subject to paragraph 4 (cross-border workers), and sets a threshold of 40 % of working time per calendar year. Its conditions are not detailed here.

Cross-border workers are subject to a separate regime. Article 17, paragraph 4, refers to the agreement of April 11, 1983, on the taxation of the remuneration of cross-border workers. This agreement forms an integral part of the convention and takes precedence over Article 17, paragraph 1, subject to Articles 18, 19, and 21. It entered into force on December 18, 1986, for remuneration received from January 1, 1985. Its content is not detailed here.

Inheritance: the 1953 agreement has ended

France notified Switzerland, by diplomatic note dated June 17, 2014, of the termination of the Convention of December 31, 1953, on Successions. It ceased to have effect on January 1, 2015, for the estates of persons deceased since that date.

The rules that now apply to an inheritance between the two countries are verified on a case-by-case basis.

What this page does not cover

The way in which double taxation is eliminated, the content of the 1983 agreement, the full conditions of § 2 b) of article 11, the other paragraphs of articles 12, 13, 15 and 17, paragraph 2 of article 20, the IFI, public functions and the special clauses remain to be read in the text.

Numerical example (fictitious profile)

Situation. A salaried employee, residing in France (fictitious profile), is employed by a French company. He makes three business trips to Switzerland during the year: 70, 55 and 40 days.

Issue. He wonders which state can tax remuneration for days worked in Switzerland. The basic rule in Article 17 § 1 refers to the state of residence, unless the employment is carried out in the other state. The exception in paragraph 2 is based on the length of stay.

Strategy. He keeps a day-by-day record of the fiscal year in question, before having the other conditions of the text examined.

Result. His three stays total 165 days: the 183-day duration requirement is met, with an 18-day margin. A fourth stay of 30 days would bring the total to 195 days: the duration requirement would no longer be met, with a 12-day excess. The other conditions of the article remain to be verified, and this example does not take teleworking into account (Article 17 § 5).

What changes depending on your situation

• Your residence as defined in the convention, which depends on your permanent home.
• The nature of the income: dividend, interest, royalty, capital gain, salary, pension.
• The location where the job is performed, the number of days spent in each state, the proportion of teleworking, and the status of cross-border worker.
• The nature of your assets: real estate or other assets.
• The possible refund of Swiss withholding tax.

An article should be read in light of the facts in your case, and no result is guaranteed in advance.