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This is undoubtedly the end of a little Swiss Eldorado for large French groups, which benefited from an administrative arrangement which caused the French state to lose money.
ECONOMY – Bye-bye the good old Swiss method. Faced with a 2025 budget that is difficult to complete, the French government is looking for the slightest opportunity to make savings. This is why he is now tackling a little-known regulation, involving neighboring Switzerland.
It must be said that the shortfall is rather impressive: up to 280 million euros lost per year, for around fifteen years. Or 4.2 billion euros since its implementation. This is what reveals The Tribune and franceinfo this Thursday, November 28, regarding this administrative arrangement dating from 2009, which allows large international French groups to benefit from a more than advantageous exemption regime in Switzerland. Under the leadership of the French executive, he is undoubtedly living his last hours.
Swiss attractiveness
The trick? It consists of employing executives from a French company in a subsidiary established in Switzerland, while having them work in France. This allows French companies to escape French social security contributions, since employees depend on the Swiss health insurance plan, LaMal. Swiss social contributions being much lower than in France, this practice could therefore be compared to social optimization. If it wasn't perfectly legal.
The two media outlets were able to consult a report from the General Inspectorate of Finance (IGF) and the General Inspectorate of Social Affairs (IGAS), produced in October 2024, examining this practice born from an administrative arrangement between France and the Switzerland on June 22, 2009.
Quoted by The Tribunea source close to the matter judges that certain French companies “ have very very limited use of this arrangement », despite its legal framework. Knowing that“there are probably abuses with French employees hired in Switzerland and immediately seconded to France”. According to the report, around twenty large French groups are concerned.
Fifteen years of losses
If relatively few employees seem to benefit from it in the targeted companies (around 4,500 between 2016 and 2022), the process undeniably causes the French State to lose money because three groups benefit more than others, with 82%. requests: Total gestion international SA, Renault Nissan Global management SA, or Michelin Global Mobility SA.
These three large companies are putting this exemption in place for very specific employees. Executives paid more than 500,000 euros per year, responsible for “ functions related to the development of an international career ». And who can benefit from this exemption for six years. No more.
So why tackle it only now? According to The Tribunediplomatic relations with Switzerland and the desire not to damage the reputation of these tricolor groups have long taken the upper hand on the French side. But not anymore. Even if it will be impossible to make up for the shortfall over fifteen years, France intends to abandon this agreement. This should be done without great difficulty since its legal framework is considered “ caricature » by the IGAS and IGF report.
According to sources from both media, the management of French Social Security recently took the necessary steps to put an end to this arrangement, which has lasted too long from the point of view of the French executive.
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