Work and location: the Tax Office clarifies the rules (cross-border guide)

Context

In a nutshell

Switzerland applies a source levy reduced to 80% of the ordinary tax. The monitoring of smart working is regulated by the maximum limit of 25% of total working hours. The employer's registered or administrative office may be outside the geographical boundary.

Key facts

• What: The clarification of the Tax on the employer's headquarters.
• When: The Revenue Agency's response came with the answer to question no. 126/2026.
• Where: Switzerland and Italy.
• Who: The Revenue Agency.
• Amount: Not specified.

Work and location: the Tax Office clarifies the rules

The Revenue Agency's response to question no. 126/2026 clarified the rules regarding the location of the employer, in particular for women workers tax resident in Switzerland who carry out their work in Italy.

The concrete case concerns a worker tax resident in Switzerland, who carries out the entire volume of her work in the territory of the Lombardy Region and returns daily to her home in Switzerland. The worker in question asked the Tax Office whether her legal or administrative headquarters could be outside the geographical perimeter of the border between Switzerland and Italy.

The answer of the Revenue Agency was affirmative, i.e. the registered or administrative office of the employer may be outside the geographical perimeter of

Operational details

Switzerland applies a source levy reduced to 80% of the ordinary tax. This regime is particularly important for workers moving between the country and abroad. The monitoring of smart working is regulated by the maximum limit of 25% of total working hours. Old border workers fall under this sub-scheme workers who worked in Switzerland at least one day between 31 December 2018 and 17 July 2023 for an employer in the Swiss border area.

On July 17, 2023, the Treasury published a circular clarifying the rules for frontier workers. This document has been created to provide clear and precise guidance on the regulations in force. Workers moving between Switzerland and Liechtenstein, for example, can enjoy a more favourable tax regime.

To be considered border workers, you must have worked in Switzerland for at least one day between 31 December 2018 and 17 July 2023 for an employer in the Swiss border area. This means that workers who have worked in cities such as Lausanne, Geneva or Zurich, for example, can be considered frontier workers. It is important to note that this scheme does not apply to all workers moving between Switzerland and abroad.

According to the tax circular, frontier workers can enjoy a more favourable tax regime. The ordinary tax is reduced to 80% and the withdrawal

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Key points

The Italian tax authorities have recently clarified the rules relating to the taxation of border workers working in Switzerland. This article explores the new rules in detail and provides concrete examples to help readers better understand the rules.

The mechanism of concurrent taxation

For new frontier workers, instead, the mechanism of concurrent taxation applies. This means that Swiss compulsory social security contributions, such as AVS (disability and old-age insurance) and LPP (old-age pension), are deductible in Italy. The same applies to Italian compulsory social security contributions.

Italian law provides for an exemption exemption of 10,000 euros. This means that if your annual income is less than 10,000 euros, you do not need to pay taxes in Italy.

Concrete example

Suppose an Italian citizen works in Switzerland and has an annual income of 40,000 euros. The employer has its registered or administrative office in the border area of the other Contracting State, or in the canton of Geneva. In this case, the Italian citizen can benefit from the exemption exemption and will not have to pay taxes in Italy.

Operational Checklists

To benefit from the exemption and deductibility of mandatory social security contributions, you must:

• Have an annual income of less than 10,000 euros
• Working in Switzerland
• Have an employer with a registered or administrative office

Check tax deadlines for cross-border workers: returns, Swiss declarations, rebates — all dates in one interactive calendar.

Source: quifinanza.it