January 2019 / Switzerland

On 11 January 2019, the Italian Tax Authorities (ITA) issued Ruling Answer No. 4/2019 providing clarifications on the favourable tax regime applicable to individuals registered in Campione d'Italia. Under article 188-bis of Presidential Decree No. 917 of 22 December 1986, qualifying individuals registered with the municipality of Campione d'Italia are subject to Italian income tax, but the computation of the part of their income that is earned in Swiss francs (for a total amount not exceeding CHF 200,000) is based on a favourable exchange rate agreed upon periodically by the competent authorities. In addition, pension and employment income earned in euros is included in taxable income only for the part exceeding EUR 6,700. The ITA clarified that, in order to benefit from this favourable tax regime, an individual must:

• be registered in the civil registry of the municipality of Campione d'Italia; or
• be registered in the civil registry of non-resident Italians (Anagrafe degli Italiani Residenti all'Estero, AIRE) of the municipality of Campione d'Italia and be a resident of Canton of Ticino (Switzerland), provided that he previously was a resident of Campione d'Italia and currently has his tax domicile there.

On 15 January 2019, the State Secretariat for International Finance (SIF) published an updated version of the position paper of 8 March 2018 outlining the Swiss position within the OECD on taxing the digitalized economy. The position paper states, among other things, that Switzerland does not currently intend to introduce interim measures such as the digital tax proposed within the European Union, as such interim measures based solely on turnover in market areas may lead to double taxation and overtaxation, and may make it more difficult to achieve a global consensus for a definitive solution.

The Federal Council in Switzerland issued a document that contains the legal bases for distributed ledger technology and blockchain in Switzerland. Download the original full document in French with an overview on the situation with particular attention to the financial sector.