Italy and Switzerland Sign New Agreement on Income Taxation of Frontier Workers: Initial Comments from an Italian Perspective

Abstract

In this note, the authors analyse – with a focus on the Italian tax implications – the new provisions regulating the income taxation of “frontier workers” in the amending Protocol to the Italy-Switzerland Income and Capital Tax Treaty (1976) and the related implementing Agreement, both signed on 23 December 2020. Once the ratification procedure is completed, the new provisions will substantially update a well-established regulatory framework dating back to the mid-1970s.