{"id":7280,"date":"2025-11-08T14:16:02","date_gmt":"2025-11-08T14:16:02","guid":{"rendered":"https:\/\/steimle-consulting.ch\/?p=7280"},"modified":"2026-05-22T08:53:49","modified_gmt":"2026-05-22T08:53:49","slug":"swiss-lump-sum-vs-italian-flat-tax-2","status":"publish","type":"post","link":"https:\/\/steimle-consulting.ch\/en\/2025\/11\/08\/swiss-lump-sum-vs-italian-flat-tax-2\/","title":{"rendered":"Swiss Lump-sum tax regime vs. Italian flat tax as from 2026"},"content":{"rendered":"
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The Italian flat tax regime for wealthy individuals who moves to Italy was introduced in 2017, while the Swiss\u00a0favourable and simplified lump-sum tax treatment has a longstanding existence as from before World War II. The Swiss regime is an “expenditure” based taxation which on one hand in principle\u00a0disregards non-Swiss\u00a0assets and income (provided the taxpayer does not have treaty favoured foreign income sources) and on the other hand considers Swiss assets (like shares or bonds issued by Swiss resident companies, cash deposited with Swiss banks, Swiss properties) and income therefrom.<\/p>\n

The Italian flat tax operates as a territorial taxation: Italian source income is ordinarily taxable in accordance to internal tax legislation, while non-Italian foreign sourced income is in principle\u00a0submitted to taxation with a “substitutive” flat tax with the exception that capital gains realized within five years from the start of the Italian tax residency on the disposal of qualified substantial shareholdings in foreign companies are taxable in Italy with a tax rate of 26%.<\/p>\n

As from 1st<\/sup> January 2026 the Italian flat tax will suffer an increase as per decision of the Italian government (to be finally approved by Parliament within the present year-end) such increased amount applicable to foreign individuals wishing to migrate to Italy as from 2026 alone or with their family members. The new flat tax will increase from the current EUR 200’000.- to EUR 300’000.- (plus EUR 50’000.- for each family member), which translated in CHF would amount to approx. CHF 278’000.- (plus approx. CHF 46’000.- for each family member). Assuming a family composed of the spouses and one child would become tax resident in Italy enjoying the special regime, the annual flat tax would amount to CHF 370’000.- which would correspond to a Swiss taxable income (Canton Ticino, municipality of Lugano)\u00a0of approx. CHF 1’000’000.<\/p>\n

This amount is more than twice the minimal Swiss lump-sum taxable income of approx.. CHF 440’000.- as fixed by the Cantonal tax authority and this would cover the taxable base for the entire three-member family as per our assumption. The annual Swiss tax burden (for all three levels of taxation \u2013 federal, cantonal and municipal), considering the minimum taxable base mentioned above, amounts to approx.\u00a0CHF 150’000\u00a0including the marginal income tax which, in compliance with the tax law, the Cantons have to assess to take into account wealth tax on the deemed taxable Swiss wealth\u00a0amounting to five times the\u00a0taxable income as agreed with the tax authority in the binding tax ruling letter.<\/p>\n

Both countries have many attractive features and a more in-depth analysis will allow to understand advantages and disadvantages of each country which for everyone, planning to move his tax residency, will judge differently. For a more detailed information of the Swiss tax regimes and Swiss migration law and procedures please read the \u00a0articles (either in English, German or Italian) on our website under the section “Insights – Location Switzerland and Canton Ticino”.<\/p>\n

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For further information on the above, please do not hesitate to contact us.<\/strong><\/p>\n

The contents of this document cannot be construed as an expression of opinion but are for information and updating purposes only. The reader who wishes to use the above information is required to consult a professional in order to ensure the fulfilment of legal and tax obligations under the regulations of his or her country of residence. Steimle & Partners Consulting SA disclaims all liability for any direct, indirect, incidental, and consequential damages for any act or omission related to the use, proper or improper use of the information contained herein. We remain available for any further discussion of the topics discussed above.<\/p>\n<\/div>

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