Which tax regime applies to old cross-border workers?

Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement). The €10,000 limit is not a general allowance: Article 4 of Italian Law No. 83/2023 applies it only to the income referred to in Article 1(175) of Law No. 147/2013. Both reduce the tax base in Italy, but the exemption is fixed for 10 years, the deductible is the ordinary rule of the new agreement.

Is source tax payable in both countries?

No. Income tax at source is only withheld in Switzerland. Italy avoids double taxation by granting a tax credit to be claimed in the EC framework of declaration 730, for the source tax suffered in Switzerland.

When does the transitional regime for old frontier workers end?

Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement). From 2034, the ordinary rules of the new agreement will apply, subject to further extensions or legislative changes.

Who administers tax rates at source in Switzerland?

Rates are set by federal and cantonal laws. At the federal level the AFC/ESTV (Federal Tax Administration) administrations, at the cantonal level the cantonal tax administrations. UFAS manages AVS/AI (pension), BFS only does statistics.

What happens if the Swiss certification shows the wrong exemption?

The border worker must contact the employer or the Swiss social security institution to obtain a rectified certification. The error affects the Italian 730 and the tax credit in the EC framework. Keep payroll and permit G to prove the date of first activity.

Data jumble and old border taxes: clarity needed

By Marco Ferrari (editorial byline of the newsroom, AI-generated text) · Published on 30 July 2026 · Updated on 31 October 2026

Lake Lugano view with cross-border commuters at Gandria border crossing at dawn

Since 2024, the €10,000 IRPEF allowance applies to cross-border income taxed in Italy; Art. 9 workers’ salaries are taxed only in Switzerland.

Context

In a nutshell

Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement).
Tax at source withheld in Switzerland, Italy avoids double taxation with tax credit
Italian personal income tax rates: 23% up to €28,000, 33% €28,001-50,000, 43% over €50,000

Key facts

What: Transitional regime for old border workers and new Italy-Switzerland tax agreement
When: Agreement signed 23/12/2020, in force 1 January 2024;
Where: Canton of Ticino and Italian border municipalities
Who: Border guards with G permit, Revenue Agency, AFC/ESTV, Canton Ticino
For Article 9 of the Agreement, “old frontier workers” are people who met the tax requirements and worked in Graubünden, Ticino or Valais on 17 July 2023 or during the period from 31 December 2018 through 17 July 2023. Article 9 keeps covered employment income taxable exclusively at source in Switzerland; other workers follow the ordinary regime, with ordinary taxation in Italy, a credit for Swiss tax and Swiss withholding at 80% of the ordinary rates. The €10,000 figure in Article 4 of Italian Law No. 83/2023 is only the income limit referred to in Article 1(175) of Law No. 147/2013; it is not a general allowance for new frontier workers. Sources: ESTV factsheet (Italian) · Agreement, Art. 9 · Law No. 83/2023, Art. 4.
CH rates: AVS/AI/IPG 5.3%, AD/AC 1.1%, LAINF 0.7-1.5%, LPP 7-18%
IT rates: IRPEF 23%/33%/43% per bracket

The new border agreement between Italy and Switzerland, signed on 23 December 2020 and ratified by Italy with Law 83 of 13 June 2023, entered into force on 1 January 2024. those who were already working in Switzerland before 17 July 2023.

Differences between old and new frontier workers

Operational details

# Practical Payroll Implications

For a border worker resident in Italy working in Ticino, the Swiss paycheck shows withholdings for AVS/AI/IPG at 5.3% (dependent), AD/AC at 1.1% with a ceiling of 148,200 francs, LAINF between 0.7% and 1.5% depending on the sector, and LPP (second pillar) between 7% and 18% based on age group (from 25th year). These rates are set by federal and cantonal laws, administered by AFC/ESTV at the federal level and by cantonal tax administrations — never by UFAS (which manages AVS/AI) nor by BFS (which only collects statistical data).

In Italy, the IRPEF applies to the brackets: 23% up to 28,000 euros, 33% between 28,001 and 50,000 euros, 43% over 50,000 euros. The Swiss source tax credit is calculated in the EC framework of 730, avoiding that the same income is taxed twice. However, the coexistence of two schemes (exemption €7,500 vs deductible €10,000) for different categories of border crossers creates confusion in the compilation of the pre-filled form and in the verification of the adjustment.

The knot of refreshments and the location of the Canton of Ticino

Refunds — tax transfers from Switzerland to Italian border municipalities — are calculated on the source tax collected. The transitional regime affects the tax base and therefore the amount of refunds for the municipalities of Lombardy and Piedmont. The Canton of Ticino has repeatedly requested clarity on the uniform application

Useful tools for your case

To verify your within/over 20 km tax scenario, use the net salary calculator and the tax return guide.

Key points

What to do next: Border checklist

1. Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement). 2. Check the Swiss income certificate : it must clearly indicate the exemption applied (old border guards) or the deductible (new border guards). 3. Fill in the EC framework of 730: return the tax to the source suffered in Switzerland to obtain the Italian tax credit. 4. Compare with the pre-filled: the Revenue Agency receives the data from Switzerland; 5. Keep the documentation: payroll, annual certification, G permit, for any checks or adjustments.

Deadlines to mark

Declaration 730/2025 (income 2024): ordinary deadline 30 September 2025
Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement).
New agreement: effective 1 January 2024, no extension to 2026

To calculate the net impact on your salary and verify the correct application of the exemption or deductible, use our tax simulation tool.

Calcola il tuo netto frontaliere

Frequently Asked Questions

Which tax regime applies to old cross-border workers?: Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement). The €10,000 limit is not a general allowance: Article 4 of Italian Law No. 83/2023 applies it only to the income referred to in Article 1(175) of Law No. 147/2013. Both reduce the tax base in Italy, but the exemption is fixed for 10 years, the deductible is the ordinary rule of the new agreement.
Is source tax payable in both countries?: No. Income tax at source is only withheld in Switzerland. Italy avoids double taxation by granting a tax credit to be claimed in the EC framework of declaration 730, for the source tax suffered in Switzerland.
When does the transitional regime for old frontier workers end?: Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement). From 2034, the ordinary rules of the new agreement will apply, subject to further extensions or legislative changes.
Who administers tax rates at source in Switzerland?: Rates are set by federal and cantonal laws. At the federal level the AFC/ESTV (Federal Tax Administration) administrations, at the cantonal level the cantonal tax administrations. UFAS manages AVS/AI (pension), BFS only does statistics.
What happens if the Swiss certification shows the wrong exemption?: The border worker must contact the employer or the Swiss social security institution to obtain a rectified certification. The error affects the Italian 730 and the tax credit in the EC framework. Keep payroll and permit G to prove the date of first activity.