{"id":3003,"date":"2026-08-26T15:56:31","date_gmt":"2026-08-26T13:56:31","guid":{"rendered":"https:\/\/balmontconseil.com\/blog\/france-suisse-les-deux-textes-qui-decident-et-celui-qui-nexiste-plus\/"},"modified":"2026-08-26T15:56:31","modified_gmt":"2026-08-26T13:56:31","slug":"france-suisse-les-deux-textes-qui-decident-et-celui-qui-nexiste-plus","status":"publish","type":"post","link":"https:\/\/balmontconseil.com\/en\/blog\/france-suisse-les-deux-textes-qui-decident-et-celui-qui-nexiste-plus\/","title":{"rendered":"France\u2013Switzerland: the two texts that decide, and the one that no longer exists"},"content":{"rendered":"
\n

In summary\u2026<\/h2>\n

Since January 1, 2015, There is no longer a convention between France and Switzerland regarding inheritance.<\/b> France denounced the 1953 border. Almost no one knows this, including those who live near the border on a daily basis.<\/p>\n

Regarding income, the 1966 agreement still applies \u2014 but an addendum signed on June 27, 2023<\/b> rewrites the rules for cross-border teleworking around a threshold of 40 %<\/b>. Switzerland approved it in June 2024; on the French side, ratification is underway.<\/p>\n

These two texts do not concern the same people, are not read in the same way, and one of the two can cost several hundred thousand euros to a family that has never opened it.<\/p>\n<\/div>\n

You work in Geneva and have switched to three days of teleworking since last year. Or your parents settled in the hills above Lausanne fifteen years ago, and you live in Annecy. In both cases, you have the vague feeling that the "Franco-Swiss convention" settles the matter.<\/p>\n

In the first case, it settles it\u2014but not in the terms you think, and the text is changing. In the second, she doesn't regulate it at all anymore<\/b>, And that's the topic we talk about most often with families who come to see us too late.<\/p>\n

1. The text that no longer exists<\/strong><\/h2>\n

Inheritance: there has been no agreement for eleven years<\/strong><\/h3>\n

The Franco-Swiss convention of December 31, 1953, governed the sharing of inheritance tax rights between the two countries. France denounced it on June 17, 2014. It ceased to apply to the estates of deceased persons. effective January 1, 2015<\/b>.<\/p>\n

Since then, there has been no sharing: each country applies its own domestic law, each on its own. And French domestic law is extensive.<\/p>\n

Specifically.<\/strong> If you live in France and inherit from a relative residing in Switzerland, France can tax everything you receive<\/b> \u2014 including assets located in Switzerland \u2014 provided you have been a French tax resident for at least six of the last ten years. Tax paid in Switzerland is creditable, but only on assets located there, and Swiss cantons often tax direct heirs little or not at all. You therefore end up paying tax in France on assets that have never had any connection to France.<\/p>\n

For the technician.<\/strong> The denunciation was notified on June 17, 2014, and took effect on January 1, 2015 (Decree No. 2014-1270 of October 30, 2014, Official Journal of November 1, 2014). The BOFiP (Official Bulletin of Public Finances) acknowledges that the convention of December 31, 1953, ceases to apply to estates opened on or after that date.<\/p>\n

In the absence of an agreement, Article 750 ter of the French General Tax Code (CGI) remains fully applicable, including the requirement that the heir or donee must have resided there for at least six of the ten preceding years. The tax credit for tax paid outside France is governed by Article 784 A of the CGI, limited to assets located outside France. Gifts are subject to the same rules.<\/p>\n

The key point is not the editing. It's that Everything is decided beforehand<\/b>. A Franco-Swiss inheritance is prepared during one's lifetime; once opened, all that remains is to pay.<\/p>\n

2. The changing text<\/strong><\/h2>\n

Teleworking for cross-border workers: the 40 threshold %<\/strong><\/h3>\n

The convention of September 9, 1966 continues to govern income and wealth tax. It has not been denounced \u2014 it has been amended.<\/p>\n

Historically, the place of taxation for a cross-border worker's salary depended on the canton. For eight cantons\u2014Vaud, Valais, Bern, Basel-Stadt, Basel-Landschaft, Jura, Neuch\u00e2tel, and Solothurn\u2014the 1983 agreement places taxation in the state of residence: the cross-border worker is taxed in France, and Switzerland pays compensation. Geneva operates differently: the salary is taxed at source in the canton, which then transfers a portion to the department of residence.<\/p>\n

This mechanism was based on a simple assumption: the cross-border worker crosses the border every morning. Teleworking shattered it \u2014 working from one's living room means working in the state of residence, which mechanically shifted the right to tax.<\/p>\n

The amendment signed on June 27, 2023<\/b> divided by a threshold: As long as the work performed remotely from the state of residence does not exceed 40 % of working time, the taxation remains unchanged.<\/b> Beyond that, the corresponding remuneration is transferred to the State of residence. For Geneva, a specific compensation mechanism applies between 15 and 40 %.<\/p>\n

Specifically.<\/strong> Over a five-day week, Two days of teleworking leave you in the system you are familiar with.<\/b> \u2014 40 %, that's exactly two days. The third day takes you out of it. This isn't a minor administrative distinction: it's a change of tax jurisdiction for a portion of your salary, with the corresponding reporting obligations. And the threshold is assessed over the year, not the week: three intensive weeks at the end of the year can tip the balance on a case that was holding until November.<\/p>\n

For the technician.<\/strong> Amendment to the convention of September 9, 1966, as amended, signed on June 27, 2023. Threshold of 40 % of annual working time for teleworking from the State of residence; specific compensation for the Canton of Geneva for the 15\u201340 % bracket. Alignment with OECD standards.<\/p>\n

The Swiss Federal Assembly approved the amendment on June 14, 2024. In France, the draft bill was examined by the Senate, the first chamber to consider it. An automatic information exchange mechanism regarding teleworking is planned from 2026 onwards\u2014this is what will make the threshold truly verifiable, and this is why inaccurate applications will not remain so for long.<\/p>\n