COVID-19: New mutual travel agreement between Switzerland and Italy for cross-border commuters - Tax and Legal blog

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Switzerland and Italy have just concluded a provisional mutual agreement, which settles the question of taxation of their respective cross-border workers (*) who are working from home. For the period from February until the end of June, cross-border commuters working from home will be deemed for tax purposes to have travelled physically to their usual place of work.

Due to travel restrictions by the Swiss and Italian governments, many cross-border workers who reside in Italy and work in Switzerland, or vice versa, have been unable to get to their ordinary place of work. This has raised the question whether this will result in a change in the tax regime applicable to them.


The agreement between Switzerland and Italy about cross-border workers who are forced to work from home due to the travel measures taken by the two governments, which applies on an exceptional and provisional basis, clarifies the tax situation. In substance, cross-border commuters working from home continue to benefit from the same tax treatment as if they had physically gone to their usual place of work. The same treatment also applies to the cross-border workers who have spent several consecutive days in their place of work without returning each day to their place of residence.

The provisions of this agreement have effect from 24 February 2020 and up to and including 30 June 2020. It is then renewable at the end of each month, and will eventually cease to have effect when the two states have ended their travel warnings and restrictions. It was already confirmed that the agreement continues to be in force for July 2020.

*Cross-border workers are those who are resident in a municipality within 20 kilometer from the borders of Canton Ticino, Grisons and Valais where the individuals commute to render their services.

Deloitte's view
This agreement reflects the recommendations made by the OECD and is a pragmatic approach which should reassure cross-border commuters and contribute to legal clarity.


If you would like to discuss more on this topic, please do reach out to our key contacts below.

Explore our collection of Swiss COVID- Tax & Legal insights designed to help companies in Switzerland to better navigate the COVID-19 crisis.

Key contacts


David Wigersma - Partner, Global Employer Services

David has 17 years of experience in the area of international corporate and individual taxation planning. He specialises in addressing the complex compliance needs of a cross-border workforce with varied elements of compensation.


Giuseppe Sarno_picture

Giuseppe Sarno - Senior Manager, Global Employer Services

Giuseppe is a Senior Manager in the Global Employer Services (GES) practice of Deloitte in Basel. He is specialised in tax, and social security compliance, as well as advisory support in the areas of tax, strategic Global Mobility advisory, technology and business traveller. Giuseppe has over 17 years of experience in providing Swiss specific and international global mobility advice to multinational corporations and their international assignee and foreign local hire population. 



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