An administrative arrangement between the two countries allows large international French groups to benefit from an advantageous exemption regime, some of their high-ranking executives thus escape French social security contributions.
Published on 28/11/2024 07:50
Reading time: 2min
Around twenty large French groups affiliate their executives in Switzerland, which allows them to avoid French social security contributions. This practice is permitted by a settlement between France and Switzerland, which caused the public accounts to lose 300 million euros each year, according to a report from Igas and the General Inspectorate of Finance dated October 2024. , which Franceinfo was able to consult on Thursday November 28.
According to a regulation between France and Switzerland dating from 2009, an administrative arrangement allows large international French groups to benefit from an advantageous exemption regime. They have the possibility of sending their executives to a subsidiary established in Switzerland, while having them work in France. These workers are thus affiliated to Lamal, the Swiss social system, which allows these groups to pay less social contributions.
Around twenty large French groups use this system; such as Total gestion international SA, Renaud Nissan Global management SA, or Michelin Global Mobility SA. The process only concerns a few employees, nearly 4,500 between 2016 and 2022. These are executives paid more than 500,000 euros annually, who occupy “functions related to the development of an international career” and who officially can benefit from this exemption for 6 years.
If the approach is not illegal, the government, in search of revenue, is looking into the subject. He estimates that nearly 300 million euros escape public accounts each year because of this regulation, this represents 4 billion euros in total, in 15 years. The government is therefore considering withdrawing from this arrangement. According to information from franceinfo, a few days ago, the Social Security department was given the green light to take action on these derogatory practices.
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