Resource article
Grenzgänger Germany-Switzerland: tax, social security and the 60-day rule 2026
How Article 15a of the Germany-Switzerland tax treaty works in 2026: the 4.5% Swiss withholding, the 60-day non-return rule, the 2025 Verständigungsvereinbarung on telework, and how to file your German Anlage N-AUS.
What you will learn
- How Article 15a works
- The 2025 Verständigungsvereinbarung on telework
- Filing Anlage N-AUS
- Common mistakes Grenzgänger make
How Article 15a works
German residents who commute to a Swiss employer are taxed in Germany on their Swiss salary, under Article 15a of the German-Swiss double-taxation treaty. Switzerland keeps a flat 4.5% withholding tax (Quellensteuer) at source. This 4.5% is credited against your German income tax liability when you file Anlage N-AUS.
To qualify as a Grenzgänger you must regularly return to your German residence. The treaty allows up to 60 days per calendar year of non-return (overnight stays in Switzerland for work-related reasons such as late shifts, on-call duty, or compulsory training). If you exceed 60 non-return days, you lose Grenzgänger status and become fully taxable in Switzerland for that year — usually a much higher tax bill.
Telework counts as 'work', not as 'non-return'. You can telework from Germany without affecting the 60-day count. But excessive telework can shift your social security back to Germany — see below.
The 2025 Verständigungsvereinbarung on telework
Before 2026, occasional telework from Germany was tolerated but the rules were unclear. The Verständigungsvereinbarung between Germany and Switzerland, in force since January 2026, formalises a 49.9% telework allowance — you can work up to 49.9% of your time from Germany without losing Grenzgänger status or shifting social security.
Additionally, up to 34 telework days per year are excluded from the 60-day non-return count entirely. This effectively means a worker doing 1-2 days of telework per week stays comfortably within the rules.
Beyond 49.9% telework, social security shifts to Germany — your Swiss employer must register with the Deutsche Rentenversicherung and pay German employer contributions, which is administratively heavy. Most Swiss employers will refuse to allow more than 49.9% telework for this reason.
Filing Anlage N-AUS
On your German tax return (Mantelbogen + Anlage N-AUS), you declare the gross Swiss salary in EUR (converted at the official German tax-office exchange rate, published yearly). The 4.5% Swiss withholding is entered as a credit; if your German tax bill is lower than the credit, you do NOT get a refund of the difference (the 4.5% is the Swiss tax floor).
Health insurance contributions to Swiss LAMal are deductible from your German taxable income as Sonderausgaben, up to the standard German caps. Contributions to a Swiss 2nd-pillar pension are also recognised under specific conditions — consult a tax advisor familiar with Swiss-German cases.
Late filing of Anlage N-AUS triggers the standard German Verspätungszuschlag (late-filing penalty: 0.25% of the assessed tax per month, minimum €25/month). If you forget to declare a Swiss bank account, the penalty is much steeper under the Außensteuergesetz.
Common mistakes Grenzgänger make
Mistake 1: assuming the 4.5% Swiss withholding is the full tax bill. It is not — your German income tax can be 25-42% depending on bracket, and the 4.5% is only credited against this. Plan your monthly cash flow accordingly.
Mistake 2: relying on the Swiss employer to handle the 60-day count. Most employers do not track this — it's the employee's responsibility. Keep a calendar of overnight stays in Switzerland for the entire year and bring it to your German tax filing.
Mistake 3: ignoring the EU framework agreement opt-in. If your employer has NOT signed the 2023 framework agreement, the old 25% telework rule applies and you risk shifting social security with relatively little telework. Always confirm with HR.
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