Case: Freya Lund – Self-Employed HR Consultant from Norway
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Freya Lund is a self-employed HR consultant from Bergen, Norway. With over ten years of experience in human resource management, she specializes in talent acquisition, organizational development, and employer branding. She works remotely for several international companies, including a leading Swiss consulting firm based in Zurich.
As her main client in Switzerland regularly organizes in-person workshops and strategy meetings, Freya travels to Switzerland approximately every two months. During these visits, she spends several days in Zurich to participate in key meetings and provide direct consulting services to her clients. However, the majority of her work is conducted from Norway, supported by virtual meetings and digital collaboration tools. Thanks to her expertise and flexibility, Freya can offer her services worldwide without being tied to a fixed location. Her business is registered as a sole proprietorship in Norway.
Immigration and tax aspects of her activity
1. Immigration Regulations
As a Norwegian citizen, Freya is part of the EFTA (European Free Trade Association), which has a free movement agreement with Switzerland. The requirements for a residence and work permit depend on the frequency and duration of her activities in Switzerland:
Short stays of up to 90 days per year
- If Freya works in Switzerland for a maximum of 90 days per calendar year, she does not need a work permit.
- However, she must register her activities with the Swiss authorities via the notification procedure for service providers. This registration is done through her own business.
Activities exceeding 90 days per year
- If Freya exceeds 90 working days per year in Switzerland, she must apply for a work permit.
- The appropriate solution would be a 120-day permit as a service provider, which is based on a contract with the Swiss company.
- A prerequisite for this permit is a verifiable, long-term contract (at least 12 months) with a Swiss company.
- This permit allows her to maintain her residence in Norway.
Permanent stay in Switzerland
- If Freya wants to live and work permanently in Switzerland, she would need to apply for a residence permit and register for Swiss social security and residency.
2. Tax and social security situation
Freya is subject to taxation in Norway, as she resides there and her business is registered in Norway. However, there are tax aspects to consider when she regularly works in Switzerland:
Income tax
- Since Freya does not maintain a permanent establishment for her business in Switzerland and only occasionally travels there for meetings, she does not establish a taxable business presence in Switzerland.
- The double taxation agreement (DTA) between Norway and Switzerland assigns the taxation rights for her self-employed income to Norway. This would change if she were to establish a permanent business presence in Switzerland.
Social security
- As a self-employed person residing in Norway, Freya pays her social security contributions in Norway.
- Based on the EFTA agreement, she can be exempted from Swiss social security obligations and remain under the Norwegian social security system.
- She must apply for the A1 certificate in Norway, which confirms her social security coverage in Norway.
3. Conclusion
- As long as Freya does not establish a permanent business presence in Switzerland, she remains taxable in Norway.
- Her stays in Switzerland must be registered via the online notification procedure.
- If she exceeds 90 working days per year in Switzerland, she requires a work permit.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
