Cross-border commuters: Ticino applies the full withholding rate (cross-border guide)

Two Ticino border workers walking along the lake

Opting for the Omnibus Decree now means being taxed in Ticino at 100% of the tables instead of 80%. There is time until the end of 2026 to regularise.

Context

Since January 2026 the Canton of Ticino withholding tax office has been applying the full rate — 100% of tables A, B, C and H — to cross-border commuters who choose the Omnibus Decree mechanism. Until 2025 the same workers were taxed at 80%, as "new cross-border commuters". The communication was made public by OCST, the canton's most representative trade union.

Who is affected

The measure concerns a specific group, which OCST calls the "old cross-border commuters from the new municipalities". These are workers who:

  • worked in Ticino between 31 December 2018 and 17 July 2023, returning home daily;
  • have their tax residence in an Italian municipality within 20 km of the border;
  • live in a municipality that was nevertheless absent from the Canton of Ticino's old list of border municipalities.

It is the last point that makes the difference, and it is the one most often misunderstood. Being within 20 km is not enough: anyone resident in a municipality already on the old list is unaffected by this communication.

A two-part mechanism

The tax burden on these workers arises from the interaction of two rules, one Swiss and one Italian.

In Switzerland they pay withholding tax, deducted by the employer on the basis of tables — A, B, C and H — that vary with family circumstances. Until 2025 Ticino applied 80% of the ordinary rate to this group, the treatment reserved for "new cross-border commuters".

In Italy, the Omnibus Decree allows workers to opt for a substitute tax equal to 25% of the withholding tax already paid in Switzerland. Adding the two together, the overall burden was broadly in line with that of "classic" old cross-border commuters: those who pay no direct income tax in Italy but are subject to the full rate in Switzerland.

Operational details

What changes

The withholding tax office has determined that anyone opting for the Omnibus mechanism is to be taxed in Ticino at 100% of the tables, no longer at 80%. The balance described above breaks down: the full Swiss rate applies, and the Italian share is added on top.

Workers face two options, each with a cost.

First option, the Omnibus route. Withholding tax at 100% in Switzerland, plus the Italian substitute tax of 25% calculated on the amount paid in Switzerland.

Second option, staying at 80%. The Swiss rate remains reduced, but the worker is classified for all purposes as a "new cross-border commuter", with the Italian filing consequences that follow.

One point deserves to be stated plainly: the "100%" here is the full rate set by the tax tables, not 100% of the salary. What changes is the percentage applied, not the entire wage.

An example with hypothetical figures

The values below serve only to illustrate how the calculation works. The actual rate depends on the applicable table, the municipality and family circumstances, and should be checked against your own salary certificate.

Assume gross annual income of 60,000 francs and a full withholding tax of 6,000 francs, that is 10% of gross pay.

  • Under the Omnibus option, 6,000 francs are paid in Switzerland, to which the Italian substitute tax is added, calculated as 0.25 × 6,000 = 1,500 francs. The total is 7,500 francs.
  • Staying at 80%, 4,800 francs are paid in Switzerland, but the position must then be handled in Italy under the rules applicable to new cross-border commuters.

The difference therefore depends on your effective rate: there is no single answer that fits everyone. For an estimate of your own case, start with the net salary calculator.

Key points

What to do now

There is time until the end of 2026 to regularise your position. The first step is working out which category you fall into, and that requires two concrete pieces of information.

1. Check your municipality of tax residence. Being within 20 km of the border is not enough: you need to know whether that municipality appeared on the Canton of Ticino's old list of border municipalities. That is the criterion separating those affected from those who are not. 2. Reconstruct your periods of work in Ticino between 31 December 2018 and 17 July 2023, with evidence of daily return. Contracts, salary certificates and employer attestations are the documents that count.

That done, the choice between the Omnibus option and the 80% rate must be assessed against the figures on your own payslip, not in the abstract: the outcome changes with the applicable table and family circumstances. A tax adviser who regularly handles cross-border cases is the right person for the simulation. OCST provides assistance to its members.

The underlying issue is political

The situation stems from an ambiguity that has dragged on for years: two countries reading the same group of workers differently. According to OCST the way out is not individual but political — action by the Italian state with Bern to settle the treatment of these workers once and for all.

Until then the choice rests with the individual worker, against a deadline set for the end of 2026. Anyone in the group described above would be well advised not to wait until the final months: reconstructing work periods and documentation takes time.

The tax return guide may help in weighing up the two filing regimes.

Source: ilgiorno.it, 25 January 2026, based on the OCST communication.

Frequently Asked Questions
Who are the "old cross-border commuters from the new municipalities"?
Workers who worked in Ticino between 31 December 2018 and 17 July 2023 with daily return home, with tax residence in an Italian municipality within 20 km of the border that was nevertheless absent from the Canton of Ticino's old list of border municipalities. Anyone resident in a municipality already on that list is unaffected.
Does withholding tax at 100% mean paying 100% of my salary?
No. The 100% refers to the full rate set by tax tables A, B, C and H, not to income. Until 2025 this group was charged 80% of the ordinary rate; now those opting for the Omnibus Decree pay the full rate.
What is the 25% substitute tax?
It is the option provided by the Italian Omnibus Decree: a substitute tax equal to 25% of the withholding tax already paid in Switzerland is paid in Italy. Combined with the Swiss 80% rate it produced a total burden similar to that of classic old cross-border commuters; with the full 100% rate the total rises.
Can I avoid the full rate?
Yes, by forgoing the Omnibus option: the Swiss rate then stays at 80%, but you are classified as a "new cross-border commuter", with the Italian filing consequences that follow. Which route is preferable depends on your effective rate and family circumstances.
What is the deadline for regularising?
There is time until the end of 2026. According to OCST the structural solution would be action by the Italian state with Bern to settle the treatment of this group once and for all.

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