General rule Where can a tax liability incur for work?
Double tax treaty Switzerland – Germany: 183 days rule with Swiss factual employer principle Less then 183 days in Switzerland in a calendar year No compensation in Switzerland No cost coverage in Switzerland Switzerland: In addition: Factual employer principle 17 Example • A controller from the German branch will come to Switzerland for 4 months • He takes over the work of his predecessor and reports directly to the head of department in Switzerland • His salary will still be payed from Germany. • His German employment contract remains unchanged • Factual employer, since integrated into Swiss organization
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