Frontierers, health tax: "A bomb behind a handful of change"

Context

On February 19, 2026, the parent company of "Civic Action for Luino and Fractions" and minority counsel, lawyer Furio Artoni, sent a press release regarding relations between Italy and Switzerland on the issue of border workers and the so-called health tax. According to the announcement, the New Frontier Agreement, applicable from 1 January 2024, was signed on 23 December 2020.

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.

Operational details

The health tax, imposed on frontier workers in the form of a monthly contribution varying from thirty to two hundred euros, was from the beginning what the writer publicly denounced: a legal abomination. I was the first – still urges Artoni –, at the local institutional level, to point out its inconsistency not only politically but structurally legal – an unconstitutional levy, incompatible with the international treaties in force and inevitably destined to trigger a reaction from the Swiss counterpart.

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Key points

The Ticino State Councillor Christian Vitta had already voiced the hypothesis at the end of January. Now it has become a formal parliamentary proposal: a motion presented to the Grand Council of the Canton of Ticino by the group leaders of PLR, Centro, UDC and Lega dei Ticinesi – Alessandro Speziali, Fiorenzo Dadò, Alain Bühler and Daniele Piccaluga respectively – asks the cantonal government to act "immediately" to suspend, totally or partially, the reimbursement to Italy of the portion of the tax at source levied on border workers, invoking the violation of Article 9 of the bilateral tax agreement by Italy.

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Source: luinonotizie.it

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.