New Italy-Switzerland cross-border workers agreement: what changes for existing and new cross-border workers

Updated September 2026 · by Dr Pier Paolo Gori

Since 1 January 2024, cross-border commuters working in Ticino, Graubünden or Valais follow different rules depending on when they started. Those who already worked as cross-border commuters between 31 December 2018 and 17 July 2023 remain taxed in Switzerland only. Those who start later are taxed in Switzerland at 80% and also in Italy, with a credit for the Swiss tax.

What is the new agreement and when does it apply?

The Agreement between Switzerland and Italy on the taxation of cross-border workers entered into force on 17 July 2023 and applies from 1 January 2024. It replaces the 1974 agreement. Italy ratified it with Law no. 83 of 13 June 2023.

Who counts as a cross-border worker under the agreement?

A person who meets all three conditions:

• lives in a municipality within 20 km of the border;

• works for an employer in the Cantons of Ticino, Graubünden or Valais (for residents of Italy);

• in principle returns home every day.

Up to 45 days a year of not returning home for work reasons are allowed, excluding holidays and sick leave. Above this threshold, cross-border worker status is lost for that year.

Existing cross-border workers: what stays the same?

Existing cross-border workers are those who worked as cross-border commuters on 17 July 2023, or at any time between 31 December 2018 and 17 July 2023.

• They pay withholding tax in Switzerland only.

• Their Swiss salary is not taxed in Italy.

• The Cantons pay the Italian border municipalities compensation of 40% of the tax revenue until tax year 2033.

New cross-border workers: how does taxation in both countries work?

New cross-border workers are everyone else, that is, those who acquire the status after 17 July 2023.

• In Switzerland they pay withholding tax at 80% of the ordinary rate.

• In Italy they declare their income and Italy grants a credit for the tax paid in Switzerland.

• Only the part of income above EUR 10,000 is taxable in Italy (Law no. 83/2023).

Switzerland and Italy exchange salary data on new cross-border workers every year.

What does this mean for an employer in Ticino?

The employer needs to know whether it is hiring an existing or a new cross-border worker, because the withholding tax rate differs. It is useful to record in the contract the place of work, days worked off-site and remote work, which has its own rules (see the guide «Remote work for cross-border workers»).

Frequently asked questions

If I change employer, do I remain an existing cross-border worker? Under the agreement, status depends on having worked as a cross-border commuter in the stated period, not on the individual employer. It is still advisable to check your own position case by case.

I live 25 km from the border: am I a cross-border worker? No. For the purposes of the agreement, the municipality of residence must be within 20 km of the border. The ordinary rules of the double taxation convention apply.

Is the new regime advantageous? It depends on income, family and municipality of residence. A simulation should be carried out with a licensed tax adviser.

How we work

Collina d'Oro Consulting SA assists Ticino businesses and employees with the legal aspects of cross-border employment: contracts, permits and corporate organisation. Tax matters are handled in coordination with licensed tax advisers.

Sources: Swiss Confederation – entry into force of the agreement · Federal Tax Administration – fact sheet on the new agreement · Italian Chamber of Deputies – Law no. 83/2023