Hands going through a tabbed file box on a wooden desk, the personnel file an employer keeps for a cross-border worker in Switzerland
07
Sep 2026
Adviser

What is deducted from a cross-border worker's salary, what depends on the canton, health insurance and the two telework thresholds, seen from the employer's side.

Reading time: 22 min

An employee who lives in France and works in Geneva receives a Swiss payslip, drawn up under Swiss rules. For the most part, you pay them like a resident: same social insurance, same compensation fund, same calendar.

Three points are the exception, and they are exactly where payroll errors cluster: tax, health insurance and telework.

Two countries and two administrations share a single payslip. The difficulty does not come from the calculation, it comes from how competence is split between the State where the work is performed and the one your employee goes home to sleep in.

This page follows a cross-border worker's salary from gross to net, from the point of view of whoever draws it up, and answers along the way what your employee will ask you about their deductions.

In brief

  • Treat your cross-border worker like a resident for social insurance, and save your attention for the three points that genuinely differ: tax, health insurance and telework.
  • Ask for the certificate of tax residence where your canton requires it, before the first day of work, because the residence permit does not decide the tax treatment.
  • Keep proof of your employee's health insurance affiliation or exemption on file, and let the cantonal authority settle their right of option.
  • Count teleworked days from the first month, because two different thresholds apply to the same employee, one for tax and one for social security.
  • Check your own canton's reporting obligations before copying a neighbouring canton's procedure, because they are not identical from one canton to the next.

Who counts as a cross-border worker under Swiss law

The term has a precise legal meaning, narrower than simply living on the other side of the border. The Agreement on the Free Movement of Persons defines an employed cross-border worker as a person who is resident in the territory of one contracting party, pursues an employed activity in the territory of the other, and returns to their place of residence as a rule daily, or at least once a week.

Source: Swiss Confederation, Agreement on the Free Movement of Persons (ALCP), RS 0.142.112.681, Annex I, art. 7 para. 1, as at 15 December 2020, verified 14 August 2026.

That last point matters. A site manager living in Pontarlier who lodges near the site in La Chaux-de-Fonds from Monday to Friday stays within the definition as long as he goes home each week.

The document that gives effect to this status is the cross-border commuter permit, better known as the G permit. An EU or EFTA national holding one can work and change jobs anywhere in the country: the SEM states that border zones no longer exist for them.

Source: SEM, G permit EU/EFTA (cross-border commuter permit), page verified 14 August 2026.

The regime for third-country nationals is stricter. The permit requires a permanent right of residence in a country neighbouring Switzerland and regular residence for at least six months in the neighbouring border zone, and the initial permit is valid only for the border zone of the canton that issued it.

Source: SEM, G permit (cross-border commuter permit), non-EU/EFTA nationals, page verified 14 August 2026.

Applying for the permit, how long it lasts and how it is renewed belong to another subject, covered by our article "Work permits in Switzerland: what employers need to know when recruiting".

Then comes the point many employers discover too late. The canton of Neuchâtel puts it bluntly: holding a G permit does not automatically confer cross-border worker status for tax purposes. The permit authorises the work, it does not decide the taxation.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

Two neighbouring situations fall outside this framework. An employee posted to you by a foreign employer is not your employee, and neither is a consultant working through a third-party company. The distinction matters in particular where a company is considering portage salarial for cross-border workers: the professional can work in Switzerland within a contractual relationship different from direct employment. Our article Portage Salarial in Switzerland: Is It Really Legal? describes that second arrangement.

Above all, remember the two variables that govern everything else: your employee's country of residence and the canton where they work.

What is deducted from a cross-border worker's salary

Every employer's first question fits on one line: do I deduct the same as for an employee living in the canton? For social insurance, the answer is yes in most cases, and the differences sit elsewhere.

Swiss social insurance: the same base as for a resident

For Swiss social insurance, it is not the employee's address that determines which system applies, as the three legal texts cited below in this section show. The official AVS leaflet also uses a numerical criterion for people working in several States: the substantial part of the activity carried out in the country of residence, set at at least 25 percent of total activity or salary.

Source: AVS/AI Information Centre, leaflet 2.12, insurance affiliation, as at 1 January 2025, verified 14 August 2026.

Your employee living in Annemasse and working full time for your Geneva company therefore contributes in Switzerland, on the same basis as her colleagues. The detail of the four contributions, what they are levied on and how they are accounted for appears in our article AVS, AI, APG, AC: understanding Swiss social security contributions, and nothing in that calculation changes because she drives back to France each evening.

Occupational pensions

Occupational pension provision follows the employment relationship, not the address on the contract. The law sets an entry threshold that mentions no residence condition: employees to whom a single employer pays an annual salary above CHF 22,680 are subject to compulsory insurance for the risks of death and invalidity from 1 January following their 17th birthday, and for retirement from 1 January following their 24th birthday.

Source: Swiss Confederation, Federal Act on Occupational Old Age, Survivors' and Invalidity Pension Provision (LPP), art. 7 para. 1, amount in force since 1 January 2025, verified 14 August 2026.

The portion of annual salary between CHF 26,460 and CHF 90,720 has to be insured: this is the coordinated salary. A developer employed at 60 percent in Lausanne therefore raises exactly the same question as a resident, that of the salary subject to contributions, and your pension institution answers it the same way for both.

Source: Swiss Confederation, Federal Act on Occupational Old Age, Survivors' and Invalidity Pension Provision (LPP), art. 8 para. 1, amounts in force since 1 January 2025, verified 14 August 2026.

Accident insurance

Accident insurance also attaches to where the work is performed. The law insures on a compulsory basis employees working in Switzerland, without setting any residence condition: your cross-border employee therefore falls under your cover like the rest of your staff.

Source: Swiss Confederation, Federal Act on Accident Insurance (LAA), art. 1a para. 1 let. a, as at 1 January 2026, verified 14 August 2026.

Premiums depend on your insurer and on your company's risk class: they cannot be quantified in an article. One precaution is still worth taking before day one, which is to have your insurer confirm cover for someone living abroad, since that is who the accident report goes to.

What does not appear on a Swiss payslip

Your payslip carries the deductions made in Switzerland. Whatever the country of residence then claims from your employee, by way of tax or social protection, does not pass through you and does not appear on that document. Many cross-border workers do not realise this when they are hired.

The net amount itself depends on the canton, on age, on family situation and on the fund chosen. We therefore publish no worked gross-to-net example: our Swiss Net Salary Calculator exists for that, and it is better to give your employee that than an estimate from memory.

Deduction Applies to a cross-border worker What changes compared with a resident
AVS, AI, APG Yes, on the basis of the work performed in Switzerland Nothing in the calculation
AC Yes Swiss contribution, benefits paid by the country of residence
LPP Yes above CHF 22,680 of annual salary paid by a single employer No residence condition in the law
LAA Yes, on the basis of the work performed in Switzerland No residence condition in the law
Health insurance Affiliation compulsory, unless an exemption is granted Premium paid by the employee directly to their insurer
Withholding tax Depends on the canton of employment and the country of residence The most variable item in a cross-border worker's payroll
Family allowances Entitlement open even where the child lives abroad, within the EU or EFTA An order of priority applies between the two countries

Tax: what the canton of employment decides

Tax is where the canton takes over. The treatment depends neither on where your company is based nor on your payroll habits, but on the canton where the work is performed and the country where your employee lives.

A long-standing agreement organises the situation with France. The agreement of 11 April 1983 between eight border cantons, namely Neuchâtel, Vaud, Valais, Bern, Solothurn, Basel-Landschaft, Basel-Stadt and Jura, and France provides, subject to conditions, that cross-border workers are exempt from withholding tax, in exchange for financial compensation of 4.5 percent of the gross payroll of cross-border workers, paid between France and Switzerland. That compensation is settled between States, it is not a charge on your payroll.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

Geneva does not appear in that list of eight cantons. A company employing people in Geneva and in Delémont therefore checks the treatment applicable to each of its two employees separately, even where their French address is identical.

The document that governs the treatment comes from the employee. In the canton of Neuchâtel, the certificate of tax residence, form 2041-AS or ASK, is given to each employer for each calendar year, in two copies, before the first day of work or before 1 January for subsequent years.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

The rest of the mechanics, meaning how the rate is set, the notification of hiring, the deduction and the payment to the administration, belongs to another subject, covered in detail by our article "Withholding tax in Switzerland: how it works for employers". You will also find there the case of foreign employees living in Switzerland.

Health insurance: the choice made in the first few months

Health insurance is the subject employers get the most questions about, and the one where their role is most misunderstood. The principle starts from the place of work: anyone working in Switzerland, along with family members not in gainful employment, has to take out health insurance there, the cover made compulsory by the Federal Health Insurance Act and universally known as LAMal. Cross-border workers who are nationals of the EU, EFTA or the United Kingdom and hold a G permit are required to insure themselves from the start of their employment contract and have three months to join a Swiss health insurer. After that deadline, they risk being assigned to an insurer automatically.

Source: Federal Office of Public Health (FOPH), health insurance, cross-border workers in Switzerland, page verified 14 August 2026.

Switzerland has, however, concluded specific agreements with Germany, Austria, France and Italy allowing EU nationals living in those countries to insure themselves in their country of residence. This is what your employee calls the right of option.

Source: Federal Office of Public Health (FOPH), health insurance, cross-border workers in Switzerland, page verified 14 August 2026.

That choice is not made through you. The exemption request is filed with the competent cantonal institution for the canton of employment, whose list the Federal Office of Public Health publishes. You are neither the authority nor the counter: your role is to inform your employee of the deadline, then keep the document they hand you.

In practice, keep either the certificate of affiliation with a Swiss insurer or the exemption decision in the personnel file. The premium does not go through your payslip, since affiliation is individual and your employee pays their insurer directly. A care assistant living in Ferney-Voltaire and hired in January by a Vaud clinic therefore has three months to join a Swiss insurer, and that is where the file is either completed or lost.

Family allowances, unemployment, accident: what follows the place of work

Three branches spring a surprise on the first real case: family allowances, unemployment and accident. Each connects the country of employment and the country of residence in its own way.

Family allowances

A cross-border worker who works in Switzerland and lives in France is entitled to Swiss family allowances for children living in France. That is what the official guide to applying the Agreement on the Free Movement of Persons sets out.

Source: FSIO, guide to applying the Agreement on the Free Movement of Persons, family benefits, verified 14 August 2026.

It gets complicated as soon as the other parent works in the country where the children live. Each child gives entitlement to only one allowance of the same kind, and where allowances are provided for the same period and the same child in Switzerland as well as in an EU or EFTA country, there is an overlap of entitlements: the person with priority is then whoever pursues a gainful activity in the State where the child lives.

Source: FSIO, family allowances, children living abroad, page verified 14 August 2026.

Your part of the work is limited to passing the claim and the supporting documents to your compensation fund, which applies that order of priority and determines what remains due. The amounts are a cantonal matter, so we do not reproduce them here.

Unemployment insurance

Here is the least intuitive point for a Swiss employer. Someone living abroad who has worked in Switzerland is in principle compensated by their country of residence, under that country's national law.

Source: SECO, travail.swiss, FAQ on unemployment benefit, page verified 14 August 2026.

They can nevertheless register with the regional employment office for the area of their last place of work in Switzerland and use its services in their job search.

Source: Swiss Confederation, ch.ch portal, how and where to register as unemployed in Switzerland, page verified 14 August 2026.

The funding does not follow the compensation. The State of residence is currently competent to pay unemployment benefits and to monitor job-search efforts, with the State of last employment reimbursing it up to five months of benefits, three months as a rule, while the contributions go to the State of employment. The word "currently" is the source's own, since a revision of the European regulation is under negotiation: no entry into force has been announced, and the position described here is that of 14 August 2026.

Source: SECO, unemployment insurance compensation body, Regulation No 883/2004 (EU), revision, verified 14 August 2026.

Accident and illness

An accident is reported to your LAA insurer, for a cross-border worker as for a resident, and only the correspondence address changes. Daily sickness benefits depend on the policy you have taken out, and their conditions cannot be generalised.

One end-of-contract point deserves a place in your offboarding procedure: the obligation to be insured in Switzerland ends at the same time as the employment contract. A mechanic hired in Delémont and dismissed in March therefore changes insurance situation on the last day of their notice period, which is worth a written reminder.

Source: Federal Office of Public Health (FOPH), health insurance, cross-border workers in Switzerland, page verified 14 August 2026.

Telework for a cross-border worker: two thresholds that are nothing alike

Telework by a cross-border worker brings two distinct rules into play, and confusing them is the most common error on the subject. One decides taxation, the other social security. The thresholds differ, the authorities that set them differ, and so do the dates they took effect. Approaching both with a single figure in mind leads to a back-payment.

The tax threshold

On the tax side, the rule for cross-border workers living in France comes from the amendment to the double taxation convention between Switzerland and France. That amendment entered into force on 24 July 2025 and applies from 1 January 2026. Within a limit of 40 percent of working time per calendar year, it provides that remuneration relating to telework is taxable in the contracting State where the employer is located.

One detail inside that percentage is easy to miss and matters in practice: the 40 percent includes a maximum of ten days of temporary assignments carried out abroad. Those days are not counted separately, they consume the same allowance as teleworked days.

Source: State Secretariat for International Finance (SIF), entry into force of the amendment to the convention between Switzerland and France against double taxation, press release of 29 July 2025, verified 14 August 2026.

This threshold is a tax threshold, and it is Franco-Swiss. For an employee living in Germany, Italy or Austria, the treatment depends on the convention concluded with that country, which this page does not go into. The full tax mechanics belong to our page on withholding tax.

The social security threshold

On the social security side, the rule has neither the same origin, nor the same figure, nor the same date. A multilateral agreement on cross-border telework provides that people working in one State for an employer based there may carry out up to 50 percent cross-border telework from their State of residence, meaning at most 49.9 percent of working time, while the State where the employer is based remains competent for social insurance. This solution has applied since 1 July 2023 with the States that signed the agreement.

Source: FSIO, telework, multilateral agreement on cross-border telework, page published 12 September 2025, verified 14 August 2026.

The agreement does not cover every situation. Someone who carries out an activity other than telework in their State of residence, someone who also works for another employer in the EU or EFTA, and self-employed people are all excluded. In those situations the agreement does not apply: which system governs is then determined under the ordinary coordination rules, to be checked with your compensation fund before the first payslip.

Source: AVS/AI Information Centre, leaflet 2.12, insurance affiliation, as at 1 January 2025, verified 14 August 2026.

What employers should record

No federal source consulted for this page imposes a general obligation to keep a record of teleworked days. The practice nonetheless imposes itself: without a record, you can demonstrate neither compliance with the tax threshold nor with the social security one, on the day an administration asks.

The canton of Neuchâtel publishes precise limits of its own, which belong to the 1983 agreement and not to the amendment described above. Under that agreement, the duration of home working and of all temporary assignments must not exceed the 40 percent telework quota, that is 96 days, and simply finding an excess of two days of temporary assignments in the State of residence makes the agreement inapplicable. Two frameworks, therefore, two sets of figures: check which one governs your employee before applying either.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

Returning home is subject to a tolerance of the same kind. For full-time work over a whole year, the same canton allows a maximum of 45 days of non-return, and at most one day per week. A sales representative living in Morteau who strings together business trips can therefore cross that limit without anyone seeing it coming.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

What employers need to put in place, in practice

Here is the order in which the steps follow one another when you hire your first cross-border worker. A missed step can always be caught up later, often at the cost of a back-payment.

  1. Check the cross-border commuter permit before the first day of work.
  2. Collect the documents: certificate of tax residence depending on the canton, proof of affiliation with a health insurer or exemption decision, bank details and family situation.
  3. Notify the employee to your compensation fund, then to the cantonal tax authority where the canton requires it.
  4. Configure the payslip: social insurance, occupational pension, and withholding tax if the canton provides for it.
  5. Open the record of days worked outside Switzerland from the first month.
  6. Update the file at every change of address, family situation or activity rate.

The first deadline is a hard figure, and it is short. The employer registers its first employee, then all its employees, with the same fund, within 30 days of the job starting.

Source: Swiss Confederation, SME Portal, unemployment insurance (AC), page verified 14 August 2026.

The second depends on the canton. In the canton of Neuchâtel, an employer of cross-border staff files the notification of hiring foreign personnel with the tax authority via Swissdec or using the dedicated form, makes sure the conditions for granting cross-border worker status are met, and returns by 31 January of the following year the declaration of remuneration paid, together with the certificates of tax residence and the list of cross-border staff by name.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

Check what your own canton requires before copying a neighbour's procedure. Our article "Payroll compliance and regulations in Switzerland" lists the reporting obligations as a whole, cross-border workers included.

This calendar takes little time when it is kept, and a great deal when it is not. Numeriq handles these notifications and declarations, with a team based in Switzerland, dedicated to payroll, that tracks the deadlines canton by canton.

The mistakes we see most often

Four mistakes come up almost every time, and none of them shows up in the month it is made. They are paid for at the back-payment, at the audit, or when the employee leaves.

The first is treating a cross-border worker like a resident on the tax side, or the other way round. It is expensive because it affects every salary paid since the hire before anyone spots it, and because putting it right means a discussion with a cantonal administration.

The second is ignoring teleworked days until an audit. Both thresholds then have to be reconstructed from memory, which rarely leaves a good impression.

The third is treating the right of option as strictly the employee's private business. The decision is theirs, that much is true, but the supporting document belongs in your file.

The fourth is letting the file go quiet after a change. A move, a birth or a shift to part-time work all affect family allowances, tax treatment and the calculation of the telework thresholds at once.

None of these mistakes is down to negligence: they come from the number of parties involved and from the fact that nobody warns you. When the load becomes uncomfortable, the Numeriq teams take over the payroll file as part of our payroll management solutions, with the declarations and deadline tracking that go with it.

Frequently asked questions

What is deducted from a cross-border worker's salary in Switzerland?

The base is the same as for an employee living in Switzerland, since social insurance follows the place where the work is performed: social security contributions, occupational pension subject to the affiliation conditions, accident insurance, and withholding tax where the canton provides for it. The health insurance premium is the exception, because affiliation is individual and does not go through the payslip.

Does a cross-border worker pay tax in Switzerland or in their country of residence?

It depends on the canton where they work and the country where they live. Eight border cantons apply the agreement of 11 April 1983 with France, which exempts cross-border workers from withholding tax subject to conditions, while other cantons do not fall under that agreement. Check your canton's position before the first payslip.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

Does the employer have to check a cross-border employee's health insurance?

You neither grant nor refuse the exemption, that competence belongs to the cantonal institution of the canton of employment. Your role is to inform your employee of the deadline running from the start of the contract, then keep in the personnel file the certificate of affiliation or the exemption decision they hand you.

How many days can a cross-border worker telework?

Two thresholds coexist and are not the same. For Franco-Swiss taxation, the amendment applicable from 1 January 2026 sets a limit of 40 percent of working time per calendar year, which also has to absorb up to ten days of temporary assignments abroad. For social security, the multilateral agreement in force since 1 July 2023 allows up to 50 percent cross-border telework, meaning at most 49.9 percent of working time. Either figure on its own is therefore never enough to answer.

Source: State Secretariat for International Finance (SIF), entry into force of the amendment to the convention between Switzerland and France against double taxation, press release of 29 July 2025, verified 14 August 2026.

Source: FSIO, telework, multilateral agreement on cross-border telework, page published 12 September 2025, verified 14 August 2026.

Do you need a G permit to hire a cross-border worker?

Yes for an employee you employ directly: the status rests on the cross-border commuter permit, known as the G permit, and the application procedure is described in our article on work permits. Draw no tax conclusion from it, however, because holding a G permit does not automatically confer cross-border worker status for tax purposes.

Source: Republic and Canton of Neuchâtel, cross-border workers, withholding tax and cross-border workers, page verified 14 August 2026.

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Mike Mansell

Mike Mansell is the Co-founder and Managing Director of Numeriq Payroll. With 16 years of experience in HR and payroll, he handles salary simulations, contracts, and questions about payslips and pensions. He enjoys turning complex payroll rules into clear, practical solutions that make life easier for businesses and employees alike.

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