Who gets my taxes?

[irlandais]

Hi all,

I'm an Irishman, living on the French side of the French/Swiss border and about to start a job in Switzerland.  I'm wondering whether I'll pay my taxes directly to France or if I'll pay some combination to both countries?  Has anyone had any practical experience of this?  What do I need to do with regard to tax before I start working?

There seem to be some very knowlegable people on this forum so may be somebody can point me in the right direction.

[Opalienne]

I know that the area around Annecy and the Canton of Geneva have a special transborder status which affects tax.   But I don;t know how it works.   Isn't this something you should ask your HR department?   They will be the experts.

[Gyn_Paul]

I would be suprised if France doesn't have a doube-taxation agreement with Switzerland. Surely if you live permanently  (i.e. more than 6 months of any year) on the French side of the boarder, then you should pay your taxes to France, reporting the gross if that's how you are (or can be paid), or reclaiming or alternatively offsetting the Swiss tax if you can only be paid net ?

But it's probably not that simple !

p

[irlandais]

Thanks for the replies. 

From what I understand, I will in fact pay my taxes to France (the tax rate seems qutie high here).  The French system is completely different to the Irish one, our taxes being deducted on a monthly basis.  I understand here, I will have to pay a tax bill in September, for everything earned form now.  I'm not quite clear on the situation, as I have heard that you pay your tax on the income earned in the previous year, and as I wasn't living in France last year, am I liable for tax?

[Pangur]

People working in the canton of Geneva are generally taxed at source by Geneva.  The Swiss then give back money to the French communes based on how many living there are frontaliers.  However, I believe other cantons have different arrangements and if you're in the UN system, its a totally different arrangement again.  It can be really confusing, and I have to warn you, HR departments are  not always clued up, depending on how many frontaliers they have.

A  really useful source of information is also this website http://www.frontalier.com/  They produce a magazine, which has articles on the many different issues frontaliers have to deal with - there's about  40,000 crossing the border each day, so you're not alone....

[Hereford]

It may depend on who your employer is.  Our son worked at CERN (8 years ago) in Geneva but "lived" in France and was "employed" by a UK agency.

The French did not want to know about him (not even for a Carte de sejour) because he left the country every day to go to work, the Swiss do not tax CERN employees (so we were told), and the UK said he was non-resident so he had an NT code.  Answer - no tax, great joy all round!!!!

The firm you are working for probably have other employees in the same position, they will be able to help you we would think.

H.

[Iceni]

As a general rule tax is initially payable wherever yr bum is parked while you are earning the money. If this were true in yr case you would pay tax in Switzerland but as you reside in France would have to declare yr worldwide income and be taxed there but anything already paid would be taken into account. No refunds of course.

BUT you need proper professionaladvice from someone who really knows.

John

not

[Pangur]

Who your employer is, and which canton in Switzerland you're working in is definitely key. 

I know that for UN and other salaried employees in Geneva, a French tax form is filled in, but you get an attestation from your employer stating where you work and they will treat it accordingly - i.e. you don't have to pay any tax in France.

There are also special medical insurance policies for frontaliers working in Geneva - as you're not paying into the French health system, you cannot use a Carte Vitale.  Instead, there are special policies for French residents working in Switzerland - most of the large French mutuelles have special Frontalier health insurance, which allow you to use French health care in essentially the exact same way as other French residents.  If you're working for an NGO or UN type bodies, they often have their own private insurance schemes.  

People working for the UN (and I think CERN) are not taxed in the same way as other French or Swiss workers - as staff comes from all over the work, there's a communal system to get over the differences in international tax law.  

People complain about red tape in France - try working in a non EU country while living in the EU and you'll truly know the meaning of the word!  Also Irlandais, there will probably be loads of people in your work in exactly the same boat and you'll have plenty of time to sort it out.

 

 

[Will]

I would confirm what Iceni says, as a general rule. The whole question of tax residency is complicated, and varies considerably between countries, even in different European states. Nowhere is it more variable than in the area around Switzerland, where there are special arrangements, and these vary even further depending on who your employer is and in which canton you are, as Opalienne and Pangur state.

French tax is indeed paid in arrears. Currently you make a declaration covering the previous calandar year in May, get a notification in Sept/Oct and pay what is due around November, though you can opt for monthly payments. What is often more relevant in France, particularly for those who are used to paying UK National Insurance, are the social charges. There are numerous calls from medical insurers, professional organisations, and providers of family allowances, retirement funds, unemployment insurances etc, all of which are collected on a pay-as-you-earn basis. If you are employed then they are not too bad, but if self-employed, or if employed on the basis that you become a French subsidiary of a foreign company, they can represent 40-60% of your earnings. So do take good professional advice which includes these charges as well as income tax. You will probably be able to benefit from any special arrangements that apply to you and it is important to get these in place from the outset. 

[irlandais]

Thank you all, your replies have been very informative.  I'll be working in the Basel area for one of the multinationals.  HR have told me I should pay French tax, this seems correct, as I was talking to a French girl today, in the same position as I am, and it is France who gets her taxes.  She was unsure though, that my situation would be the exact same, being a non-French national. 

I think professional advice will be required, but if the information I have is correct, what must I do now, to be able to pay tax?

[Iceni]

Get the professional advice NOW before you make any decisions about WHERE. The big prob IMHO is not tax but cotisations and AFAIK double taxation agreements only cover tax.

Those of us who have replied to your question are well meaning folk but cross border taxes etc are v complicated and every circumstance is different.

John

not

 

[irlandais]

I telephoned Gether MacGeorge in Basel, who give tax advice to expats.  They informed me, that no double taxation scheme will apply and as I live in France, I will be exlusively under the French system.