As neighbours, the Swiss and the Germans are said to be culturally quite similar. Both value punctuality and thoroughness and attach great importance to getting things right. It is no different when it comes to tax and social security. It is therefore no surprise that the legal framework is generally clearly defined and that, unlike with other countries, special rules and exceptions apply. Cross-border commuters, people with dual residence and companies whose employees work in the other country on shorter or longer assignments know the challenges well: local law in Germany and Switzerland adds complexity on top of the double tax treaty, deadlines are rigid and the formalities can quickly turn into a paper war. On top of that, the Swiss adviser does not understand the German side, and the German adviser waves off Swiss questions.
That is now changing: Haug Tax & Payroll in Switzerland and Steuerkanzlei Gärtner in Germany are joining forces to offer you a coordinated cross-border solution.
Two local specialists – one coordinated approach.
What can go wrong in cross-border cases
In many cross-border engagements, the risk of error lies not in the complexity of individual rules but in the lack of coordination between the two countries. Swiss tax advisers can recalculate Swiss withholding tax and prepare a clean tax return. Whether the client has correctly claimed the tax credit in Germany is beyond their knowledge. Conversely, a German adviser can properly review exit taxation. Whether the move to Switzerland was structured optimally – for example with regard to the choice of canton or pension provision – remains a blind spot.
Especially when it comes to crediting withholding taxes or allocating salary between Germany and Switzerland to avoid double taxation, the 60-day rule and relocations in either direction, a lack of coordination between both sides often leads to unnecessarily high coordination effort. It is not always guaranteed that double taxation can be avoided completely and that deadlines are met. Each individual issue can usually be handled. Coordinating all of them, with the right timing, rarely succeeds without a partner on the other side.
Six situations in which we can make a real difference
Cross-border commuters Germany – Switzerland / Switzerland – Germany
You live in one country and work in the other – in either direction: residence in Germany with a place of work in Switzerland, just as much as residence in Switzerland with an employer in Germany. We are happy to take care of withholding tax, the 60-day rule, home-office days and the Gre forms (Gre-1, Gre-2 and Gre-3). We align both sides and coordinate the crediting of withholding tax to avoid double taxation, or the reduction of the German salary taxable in Switzerland to 80%.
Dual residence
Family in one country, work in the other. This is one of the most delicate constellations from a tax perspective, and it must be clarified in which country the person has limited and in which unlimited tax liability. We check where a tax return has to be filed, coordinate social security, ensure that withholding taxes are credited and prepare a clean international tax allocation – with the aim of avoiding double taxation between Germany and Switzerland.
Moving between Germany and Switzerland
You are relocating your residence between Germany and Switzerland. This raises questions about exit taxation, taxation on arrival, the choice of canton and what happens to your pension provision. Planning ahead can lead to significant tax savings. Corrections after the fact lead to higher costs and unnecessary administrative effort.
Companies with cross-border employment
German companies with employees in Switzerland may face topics such as ANobAG (employee of a non-Swiss employer), accident insurance and occupational pension provision (BVG). Swiss companies with employees in Germany have to deal with the German system. We ensure legally compliant handling in both countries.
Managing directors and senior executives (Art. 15(4) DTA)
A special rule applies to managing directors and senior executives in cross-border situations: Article 15 paragraph 4 of the double tax treaty and the consultation agreement between Germany and Switzerland. Where these apply, they can have a major impact on the tax burden. We review and assess their applicability to your specific situation.
Employee assignments in Germany and Switzerland
If your employees work in the other country for shorter or longer periods, the question arises whether there is a risk of a de facto employer in the host country. This can have far-reaching tax and social security consequences. We assess the risk and avoid double taxation before it becomes a problem.
Your benefit
Our coordinated cross-border advice gives you certainty that all your Swiss and German affairs are aligned efficiently from a tax and social security perspective. Your coordination effort is kept to a minimum, as two local specialists take care of your affairs. Your contact person coordinates all questions directly with the partner in the other country. You explain your situation only once, in a call with both sides, and you can contact the person responsible in either country at any time.
This saves you the time of searching for a second adviser, coordinating between two firms and making your own enquiries with the authorities. Both firms remain independent, and the other country is only brought in where necessary. You receive competent advice from two local specialists with a coordinated approach and a transparent cost estimate upfront.
Getting a clear answer is simple
Getting in touch is easy: contact us by email or phone, and we will confirm the appointment for a free 15-minute initial consultation. In it, we clarify whether your situation genuinely has a cross-border dimension and where the key issues lie. It often becomes clear at this stage whether advice in one country is sufficient or whether both countries need to be coordinated. If one jurisdiction is enough, we will tell you openly. Afterwards, each firm involved sends you its own proposal with a clear allocation of roles and a cost estimate. You know from the outset what you will pay in total and decide for yourself how to proceed. There is no obligation until you confirm.
Get in touch
Please contact us with three suggested time slots for your free initial consultation and outline your situation in three to five sentences:
Further information on our qualifications can be found on our page Tax advice Germany–Switzerland, and a contact form on my contact page.
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