Cross-border health tax: Lombardy stands alone, Ticino threatens retaliation

Lombardy is the only Italian region pushing for the implementation of the 'cross-border health tax' for frontier workers, which came into force 27 months ago but has never been applied. The Canton of Ticino has threatened to reduce reimbursements in response.
Context
TL;DR
- Lombardy to discuss repealing 'health tax' for cross-border workers on April 14, 2026.
- Tax violates 2020 Italy-Switzerland agreement, per CGIL trade union.
- Lombardy is the only region pushing for the tax implementation.
Key facts
- Data discussione: 14 aprile 2026
- Regione: Lombardia
On Tuesday, April 14, the Lombardy Regional Council will discuss a motion introduced by Democratic Party councillors Samuele Astuti and Angelo Orsenigo. The goal is to urge the Italian government to repeal the 'health tax' for cross-border workers, a levy introduced in the budget law but never enforced. Giuseppe Augurusa, national coordinator for cross-border workers at the CGIL trade union, has bluntly described the tax as a violation of international law: > 'What the legislator calls a 'contribution' is, in fact, a tax and breaches the 2020 Italy-Switzerland agreement, which became law in 2023.' According to the CGIL, 'old' cross-border workers already under a transitional regime should be taxed exclusively in the country where they work, namely Switzerland.
The so-called health tax is the contribution to the Italian National Health Service set by Law 213/2023 (Art. 1, paragraphs 237-239): from 3% to 6% of the net salary earned in Switzerland, with a minimum of 30 and a maximum of 200 euros for each month worked, set each year by the region of residence.
The 2020 agreement and its repercussions
The agreement was signed on December 23, 2020 and ratified in 2023. The Italian government’s plan to introduce an additional levy on income already taxed at source, without any link to individual services provided, represents, in the CGIL’s view, a direct violation of the agreement. > 'If enforced, the law would inevitably end up before the Constitutional Court,' Augurusa warned. The union’s stance has been reiterated ahead of the Lombardy Regional Council debate, where the PD’s motion could mark a turning point.
Reactions from the Canton of Ticino
Ticino officials have already labelled the tax as contrary to the double taxation agreement. The threat of retaliatory measures concerns reimbursements—transfers Switzerland pays to Italian border municipalities under tax agreements. > 'Reimbursements are crucial for the budgets of many Lombard municipalities, which rely on these funds to provide public services,' a Ticino Department of Finance official noted.
Divisions within Italy
While Piedmont, Aosta Valley, and South Tyrol have largely ignored the levy, Lombardy remains the only region pushing for its implementation—a move that, according to internal sources within the majority coalition, lacks unanimous support. Contradictory statements between the regional president and some majority councillors have already highlighted internal divisions. The hearing of the relevant assessor has been postponed indefinitely, but the PD’s motion represents a first concrete step toward demanding a review of the legislation.
Operational details
The failure to implement the 'health tax' for over two years has created a regulatory limbo that exposes cross-border workers to daily uncertainties. For many of them, the current situation translates into a double uncertainty: tax-related, due to the unenforced rule, and employment-related, as potential retaliatory measures on reimbursements could impact local public services.
The so-called health tax is the contribution to the Italian National Health Service set by Law 213/2023 (Art. 1, paragraphs 237-239): from 3% to 6% of the net salary earned in Switzerland, with a minimum of 30 and a maximum of 200 euros for each month worked, set each year by the region of residence.
What changes for 'old' and 'new' cross-border workers
Cross-border workers are divided into two categories: 'old' and 'new'. The former (Art. 9 of the 2020 agreement) are taxable only in Switzerland, with no time limit. For the latter (Art. 3), Switzerland taxes up to 80% and then Italy taxes and eliminates double taxation.
Possible scenarios
Two main scenarios are emerging: the first involves Lombardy abolishing the rule, thus avoiding a legal dispute with Switzerland. The second, riskier scenario, would entail the tax being applied and Switzerland responding accordingly. In this case, Lombard municipalities could lose part of the reimbursements. 'This would lead to immediate cuts to services such as road maintenance and basic healthcare,' stated a mayor from the province of Varese.
The role of the federal government
The government in Bern, a signatory to the 2020 agreement, has yet to officially express its position. Its stance is expected to be decisive in resolving the situation.
'What the legislator calls a 'contribution' is, in fact, a tax and, as such, violates international law' — Giuseppe Augurusa, CGIL frontalieri
Useful tools to protect your net income
To reduce FX leakage, compare CHF-EUR exchange options and banks for cross-border workers.
Key points
For cross-border workers and the municipalities concerned, the discussion in the Lombardy Regional Council on Tuesday, April 14, represents a crucial moment. Here’s what to do to prepare for possible scenarios.
The so-called health tax is the contribution to the Italian National Health Service set by Law 213/2023 (Art. 1, paragraphs 237-239): from 3% to 6% of the net salary earned in Switzerland, with a minimum of 30 and a maximum of 200 euros for each month worked, set each year by the region of residence.
Step 1: Verify your category
Cross-border workers must distinguish between:
- 'Old' cross-border workers: Art. 9 of the 2020 Agreement, taxable only in Switzerland.
- 'New' cross-border workers: Art. 3 of the 2020 Agreement, Switzerland taxes up to 80%, then Italy taxes and eliminates double taxation.
Step 2: Monitor official communications
The Lombardy Region will publish the outcomes of the PD motion on its institutional channels. Workers can subscribe to the newsletters of border municipalities (Varese, Como, Lecco) to receive timely updates.
Step 4: Download useful tools
To calculate the current tax impact and simulate future scenarios, we recommend using the cross-border worker salary calculator by Frontaliere Ticino.
Key deadlines to remember
- April 14, 2026: Discussion of the PD motion in the Lombardy Regional Council.
Source: varesenews.it
Frequently Asked Questions
- Is the "health tax" for cross-border commuters already in force in Lombardy?
- No. The rule came into force 27 months ago, but has never been applied. The discussion in the Lombardy Regional Council on April 14, 2026 could lead to its repeal or the start of procedures for its application.
- What happens if Lombardy applies the health tax?
- According to the CGIL, the rule would violate the 2020 Italian-Swiss agreement and would land at the Constitutional Court. At the same time, Switzerland threatens retaliation on rebates, with possible cuts to public services in border municipalities.
- What are the differences between old and new cross-border commuters according to the 2020 agreement?
- Old cross-border workers, under a transitional regime, are subject to exclusive taxation in Switzerland without time limits. For new workers, Switzerland applies taxation of up to 80% of withholding tax, while Italy proceeds with residual taxation by eliminating double taxation. This distinction is essential to determine the tax obligations of each category of worker.
- What do Lombardy municipalities risk if the health tax is applied to cross-border commuters?
- The application of the health tax could trigger retaliation by the Canton of Ticino regarding rebates, i.e. the financial transfers that Switzerland pays to Italian border municipalities. The loss of these funds would lead to immediate cuts to local public services, including road maintenance and basic health care, putting the budgets of the Lombard municipalities concerned in serious difficulty.
- Which other Italian regions besides Lombardy have introduced the health tax?
- Currently, Lombardy remains the only region to insist on the possible application of this contribution. Other regions involved in the cross-border phenomenon, such as Piedmont, Valle d'Aosta and South Tyrol, have essentially ignored the rule provided for by Law 213/2023, avoiding starting the process for the introduction of this additional levy on the wages of cross-border workers.
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