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Fidinam & Partners Newsletter - April 2022

Publications Fidinam & Partners

The Fidinam & Partners Newsletter is online! In this issue, news of Swiss and international tax advice.

In this issue:

Switzerland: Intercantonal company delocalisation and tax domicile

On 10 September 2001, the Tax Division of the Federal Department of Finance communicated the data relating to persons taxed on a expenditure-based (lump-sum) basis in the Canton of Ticino.
Foreign nationals domiciled in Ticino amounted to 910 as at 31.12.2016, 842 as at 31.12.2018 and 896 as at 31.12.2020.
This method of taxation allows the taxpayer not to file an ordinary (worldwide) tax declaration but to declare exclusively the taxable income from Swiss sources. For some wealthy foreign taxpayers who have moved to the Canton of Ticino, this method must be studied in advance, as some double taxation agreements provide restrictions, which can be overcome by applying the socalled modified global taxation. 

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Italy: taxion of work done in transnational mode
With several practical interventions in the first month of 2022, the Italian Revenue Agency has provided its clarifications on several cases concerning the application of the special regime for inbound workers becoming tax resident of Italy under Article 16 of
Legislative Decree no. 147/2015 also related to cases of work carried out on a transnational basis (i.e. those cases in which a worker resident in Italy performs his duties on behalf of a non-resident employer), which due to the effects of the pandemic has affected and still affects an increasing number of workers and employers. In the following, after an illustration, albeit very brief, of the requirements for apply to the favourable tax regime in argument, we will proceed to highlight the various clarifications of practice recently provided on the subject by the Revenue Agency.

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