Can the company be based in Milan if I work on the border?

Yes, according to the Revenue Agency's request 126/2026, the employer's registered or administrative office can be located anywhere, even outside the border area. What matters is that the work is carried out physically within 20 km of the border and that the worker resides in a border municipality with daily return.

What are the taxes for a new border worker hired after July 17, 2023?

New frontier workers are subject to concurrent taxation. Switzerland levies a tax at source equal to 80% of the ordinary tax. In Italy, the income must be declared with an exemption of 10,000 euros. You can deduct AVS and LPP contributions and get a tax credit for taxes already paid in Switzerland to avoid double taxation.

What happens if I exceed 25% of smart working?

Exceeding the threshold of 25% of total working time in teleworking mode entails the immediate loss of the status of tax frontier. In this case, the worker loses the right to the benefits of the 2020 Agreement and his income is taxed according to the ordinary rules, without specific deductibles.

Frontier workers: it matters where you work, not the company headquarters (cross-border guide)

Di Marco Ferrari · Published on 30 July 2026

The Revenue Agency clarifies: the tax regime of frontier workers depends on the place of the physical service, not on the employer's address.

Context

In a nutshell

The employer's registered office may be outside the border area
Counts the physical place where the work is performed
Basic requirement: residence within 20 km of the border
The limits for teleworking set at 25% per year have been confirmed

Key facts

What: Answer question no. 126/2026 Revenue Agency
When: Enforcement of post-Agreement 2020 legislation
Where: Border area (Lombardy, Piedmont, Ticino, Graubünden)
Who: Scientific informant resident in Ticino
Amount: Deductible of 10,000 euros for new frontier workers

The Revenue Agency has dissolved an interpretative knot that burdened thousands of cross-border workers through the answer to call no. 126/2026. The case under consideration concerns a worker residing in a Swiss border municipality in the Canton of Ticino, employed as a scientific informant of the drug. The professional operates entirely in Lombardy, therefore within 20 km of the Swiss border, but on behalf of a company that has its registered office in Veneto, a region totally unrelated to the map of border areas. The central question was whether the geographical location of the employer's administrative headquarters could preclude access to the preferential tax regime provided for by the New Agreement between Italy and Switzerland.

The primacy of physical performance

The Tax Office has determined that the tax status of the worker is governed by

Operational details

Old and new border crossers: the differences in the withdrawal

The Revenue Agency's clarification fits into a tax system now divided into two distinct tracks. The so-called old frontier workers are those who worked in Switzerland for at least one day between 31 December 2018 and 17 July 2023. For this category, the agreement guarantees the maintenance of the exclusive taxation regime at source in Switzerland, with a total IRPEF exemption in Italy. This right remains valid even in the event of a change of employer, provided that the interruption of the relationship does not exceed 12 months and that the new employment remains in the border area.

The New Hire Mechanism

For those who started the business from 18 July 2023, the situation changes radically towards a competing taxation model. In this scenario, Switzerland applies a reduced source tax, equal to 80% of the ordinary tax calculated according to the cantonal tables. The worker is then required to present the dichiarazione dei redditi in Italy. Here, the entire income is subject to IRPEF taxation, but with specific mitigation mechanisms: an exemption deductible of 10,000 euros and the full deductibility of Swiss mandatory social security contributions, such as AVS and LPP. To avoid double taxation, a tax credit is recognized for what has already been paid to the Swiss authorities.

A critical aspect concerns the management of the smart

Key points

Procedures and checks for the worker

To benefit correctly from the tax regime, the worker must ensure that their contractual and logistical situation complies with the parameters defined by interpello 126/2026. The first step is to verify the kilometric distance between the municipality of residence and the border, which must be less than or equal to 20 km. Subsequently, it is necessary for the employment contract or a statement from the employer to clearly specify that the performance takes place within the border area, regardless of where the company's legal headquarters is located. This document is essential in case of checks by Italian tax authorities.

Declaration obligations and deadlines

New border workers must pay particular attention to the completion of specific tables in the Redditi or 730 model. It is necessary to report the Swiss gross income, deduct pension contributions and apply the €10,000 exemption. The calculation of the tax credit requires proof of payments made in Switzerland for income tax at source. Even old border workers, although enjoying exemption, must monitor any changes in their situation, such as exceeding the 12-month inactivity limit that could make them lose the transitional regime of favor.

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Frequently Asked Questions

Can the company be based in Milan if I work on the border?: Yes, according to the Revenue Agency's request 126/2026, the employer's registered or administrative office can be located anywhere, even outside the border area. What matters is that the work is carried out physically within 20 km of the border and that the worker resides in a border municipality with daily return.
What are the taxes for a new border worker hired after July 17, 2023?: New frontier workers are subject to concurrent taxation. Switzerland levies a tax at source equal to 80% of the ordinary tax. In Italy, the income must be declared with an exemption of 10,000 euros. You can deduct AVS and LPP contributions and get a tax credit for taxes already paid in Switzerland to avoid double taxation.
What happens if I exceed 25% of smart working?: Exceeding the threshold of 25% of total working time in teleworking mode entails the immediate loss of the status of tax frontier. In this case, the worker loses the right to the benefits of the 2020 Agreement and his income is taxed according to the ordinary rules, without specific deductibles.