When did the New Frontier Agreement come into force?

The New Frontier Agreement entered into force on 1 January 2024. The agreement had previously been signed on 23 December 2020 and ratified by the Italian State through Law 83 of 13 June 2023.

What is the difference between old and new frontiersmen?

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)](https://www.estv.admin.ch/dam/it/sd-web/Zbr5Jb-40aYm/int-laender-it-faktenblatt-faqs-it.pdf) · [Agreement, Art. 9](https://www.fedlex.admin.ch/eli/cc/2023/410/en) · [Law No. 83/2023, Art. 4](https://www.normattiva.it/atto/caricaDettaglioAtto?atto.articolo.numero=4&atto.codiceRedazionale=23G00087&atto.dataPubblicazioneGazzetta=2023-06-30&bloccoAggiornamentoBreadCrumb=true&classica=true&dataVigenza=09%2F09%2F2026&generaTabId=true&tipoDettaglio=singolavigenza&title=lbl.dettaglioAtto). 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.

Is income tax paid in both countries?

No, income tax at source is only withheld in Switzerland. Italy avoids double taxation by allowing the worker to apply for a tax credit through the EC framework of declaration 730.

Lite Lombardy and Switzerland: the tax hub for border workers

By Marco Ferrari (editorial byline of the newsroom, AI-generated text) · Published on 23 July 2026 · Updated on 31 October 2026

Analysis of the dispute between Lombardy and Switzerland over the tax treatment of old border workers and the impact of the new agreement in force since 2024.

Context

In a nutshell

New Frontier Agreement in force from 1 January 2024
Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement).
Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement).
Withholding tax at source made in Switzerland

Key facts

What: Tax dispute between Lombardy and Switzerland
When: New agreement in force from 1 January 2024
Where: Canton of Ticino and Lombardy Region
Who: Old and new frontier workers, MEF, Revenue Agency
Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement).

The tax management of cross-border workers between Italy and Switzerland has entered a new phase with the implementation of the New Frontier Agreement, signed on 23 December 2020 and ratified in Italy with Law 83 of 13 June 2023. This agreement is fully operational from 1 January 2024, redefining the taxation relations between the two States.

The structure of taxation

A key point, often subject to confusion, concerns the tax at source on income from work. This deduction is made in Switzerland for frontier workers. Italy, in order to avoid the worker being taxed twice on the same income, applies the tax credit mechanism, which is technically managed through the CE framework of the tax return 730. This system ensures that the tax paid in Switzerland is recognised in the calculation of taxes due in Italy.

The frame

Operational details

Transitional Regime and Differences

The implementation of the new agreement has created a clear distinction between two categories of workers based on the date of July 17, 2023. This date serves as a dividing line to determine which fiscal regime to apply, introducing a transitional period aimed at mitigating the impact of the change for those already active in the Ticino labor market.

Old vs New Frontalieri

Old cross-border workers remain taxed only in Switzerland (Art. 9 of the 2020 Agreement). The €10,000 threshold in Article 4 of Italian Law No. 83/2023 applies exclusively to employment income earned continuously and exclusively by Italian residents in a foreign border area or neighbouring country, as referred to in Article 1(175) of Law No. 147/2013; it is neither a general allowance nor an exemption from Swiss withholding tax.

To understand the practical impact, it is useful to observe how costs and deductions vary. While the source tax remains Swiss, the mandatory contributions follow precise rules. For example, the AVS/AI/IPG contributions are 5.3% of the employee's salary, while the unemployment insurance (AD/AC) is 1.1% up to a ceiling of 148,200 CHF. The professional pension (LPP) varies between 7% and 18% depending on the age bracket, starting from 25 years old.

Table 1: Category
Category	Requirements and tax treatment	Transitional period	Swiss contributions (example)
Article 9: old frontier workers	Tax requirements and work in Graubünden, Ticino or Valais on 17 July 2023 or from 31 December 2018 through 17 July 2023; covered wages are taxed only in Switzerland	2024–2033	AVS/AHV 5.3% + AD/AC 1.1%
Other frontier workers	Ordinary regime: Italian tax with credit for Swiss tax; Swiss withholding at 80% of ordinary rates. The €10,000 limit applies only to income referred to in Article 1(175) of Law No. 147/2013	From 2024	Same contribution rates, as applicable

This differentiation is at the center of discussions between the regional authorities in Lombardy and those in Switzerland, as the interpretation of the nature of these deductions and their respective allowances can vary, influencing the tax revenues of local administrations in Italy. Those who wish to verify their net amount can use a calculator to simulate the impact of the IRPEF aliquots in Italy.

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

Practical Guide to Tax Management 2024-2033

For workers operating between Italy and Ticino, accurate documentation management is the only way to avoid penalties or incorrect tax application. The declaration process must be precise, especially for those under the transitional regime for old frontier workers.

Step-by-Step Declaration Procedure

1. Collect documents: Obtain the Swiss salary certificate that confirms the tax withheld at source and the pension contributions (AVS, LPP). 2. The €10,000 threshold in Article 4 of Italian Law No. 83/2023 applies exclusively to employment income earned continuously and exclusively by Italian residents in a foreign border area or neighbouring country, as referred to in Article 1(175) of Law No. 147/2013; it is neither a general allowance nor an exemption from Swiss withholding tax. 3. Compile 730: Enter the income earned in Switzerland in the CE box of the Italian income tax declaration. 4. Calculate tax credit: Verify that the tax paid in Switzerland has been correctly deducted from Italian taxes to avoid double taxation. 5. LAMal Control: If you have a G permit, verify the option chosen for the illness insurance, remembering that the franchises for adults vary between 300 and 2.500 CHF.

Pension and Insurance Obligations

It is essential to monitor contributions to LPP and AVS. While AVS is a mandatory pillar, the accident insurance (LAINF) has deductions that oscillate between 0.7% and 1.5%. Regarding health, the LAMal insurance is not a tax but an insurance system where the frontier worker with a G permit can exercise a right of option.

For those with doubts about their fiscal position or who want to understand how the Italian IRPEF (with brackets from 23% to 43%) affects their net salary after the Swiss source tax, it is advisable to use simulation tools. For a precise calculation of the pay slip and taxes, it is possible to access the calculator of Frontaliere Ticino.

⚠️ VIRGOLETTE NEI VALORI JSON: if you report a term or phrase cited between quotes (e.g., the so-called "health tax"), do not use the character " inside a string value JSON — use single quotes ('health tax') or guillemets («health tax»). If you must use double quotes internally, escape them with " (e.g., "the so-called "health tax"). A double quote not escaped inside a string makes the entire JSON invalid and discards the entire article.

Article 1(237–238) of Italian Law No. 213/2023 does not apply indiscriminately to all cross-border workers. It covers: (a) Italian residents who work and stay in Switzerland and use the Italian SSN; (b) frontier workers under Article 9(1) of the Italy–Switzerland Agreement whose income is taxable only in Switzerland and who exercised the legal right to choose health insurance; and (c) dependants of those two categories. Paragraph 238 sets a progressive 3–6% share of net Swiss salary, with a €30 minimum and an ordinary €200 maximum for each month worked from 2024. The cap may be doubled in cases of omitted payment or omitted communication specified in Article 1(100) of Law No. 207/2024. The Region of residence sets the rates and procedure each year.

Frequently Asked Questions

When did the New Frontier Agreement come into force?: The New Frontier Agreement entered into force on 1 January 2024. The agreement had previously been signed on 23 December 2020 and ratified by the Italian State through Law 83 of 13 June 2023.
What is the difference between old and new frontiersmen?: 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. 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.
Is income tax paid in both countries?: No, income tax at source is only withheld in Switzerland. Italy avoids double taxation by allowing the worker to apply for a tax credit through the EC framework of declaration 730.