The tax framework for cross-border workers between Italy and Switzerland continues to raise regulatory and interpretative issues that deserve attention. Among the most widely discussed topics are the Italian contribution intended to fund the National Health Service, commonly referred to as the “healthcare tax”, and the tax treatment applied in Ticino to certain workers who opt for the regime provided for under the so-called Omnibus Decree.
Although both issues concern cross-border workers, they have different underlying conditions, target groups and consequences. It is therefore important to distinguish between them, verify which provisions actually apply and monitor developments in the respective procedures.
What is the so-called healthcare tax for cross-border workers?
The so-called healthcare tax is a contribution provided for under Italian legislation for certain categories of cross-border workers. The measure was introduced by the 2024 Budget Law and was subsequently subject to implementing provisions.
The contribution is intended to fund the National Health Service in the border regions concerned. The rules provide for an amount calculated by applying a rate of between 3% and 6% of net income, with a minimum of EUR 30 and a maximum of EUR 200 per month.
The measure applies in particular to so-called “old cross-border workers”, meaning workers covered by the specific transitional arrangements under the Agreement between Italy and Switzerland on the taxation of cross-border workers.
It is therefore not a contribution that automatically applies to anyone residing in Italy and working in Switzerland. To determine whether an individual falls within the relevant category, their personal circumstances and the requirements laid down by law must be examined.
Is the healthcare tax already in force in practice?
It is essential to distinguish between the existence of a legislative provision and its actual implementation.
In December 2025, a ministerial decree was published allowing the border regions to define the practical arrangements for the contribution. However, according to the latest OCST update identified, dated 23 June 2026, Lombardy, Piedmont and Aosta Valley had not yet adopted their respective regional measures, and no workers had been asked to pay the contribution.
As of today, it has not been possible to confirm through a regional institutional source that the levy has subsequently been implemented on a general basis. It would therefore be incorrect to state that the healthcare tax has been definitively abandoned, but equally incorrect to present it as a payment already being demanded from all workers concerned.
For individual cases, the relevant regional measures and the latest official communications should be checked.
Why is the healthcare tax being challenged?
The measure is the subject of a legal and institutional debate involving trade unions, the Canton of Ticino and the Italian and Swiss authorities.
According to a legal opinion commissioned by the Ticino Council of State from the University of St. Gallen, the contribution would be essentially fiscal in nature and could be incompatible with Article 9 of the Agreement between Italy and Switzerland on the taxation of cross-border workers.
Questions have also been raised about the measure’s compatibility with the principles governing the free movement of persons between Switzerland and the European Union.
It is important to clarify that these are legal assessments and interpretations which, in themselves, do not amount to a final judgment or the annulment of the provision. The positions expressed by the different parties involved do not necessarily coincide.
The situation should therefore continue to be monitored carefully, without assuming either the outcome of the challenges or the actual implementation of the contribution.
What is the Omnibus Decree regime for cross-border workers?
The so-called Omnibus Decree, introduced in 2024 and subsequently converted into law, provided for a specific tax election for certain categories of cross-border workers.
The measure was designed to address some of the difficulties that emerged following the implementation of the new Italy–Switzerland Agreement, particularly for workers residing in Italian municipalities included in the new list of border municipalities but not included in the previous lists.
For individuals who meet the prescribed requirements, the regime allows them to opt in Italy for a substitute tax in place of personal income tax (IRPEF) and the relevant additional taxes. The substitute tax is calculated at 25% of the taxes applied in Switzerland, subject to the conditions laid down by law.
This option is not automatically available to all cross-border workers. It is necessary to verify whether the individual belongs to the relevant category and meets the legal requirements.
What changed in January 2026 for certain cross-border workers in Ticino?
An update concerns workers residing in the new Italian border municipalities who choose the Omnibus Decree regime.
According to information provided by the Ticino Cantonal Tax at Source Office, since January 2026 Swiss withholding tax has been applied at 100% for these workers, rather than the 80% previously used for the category concerned.
This change may affect the overall tax outcome of the election, since the Italian mechanism is linked to the tax applied in Switzerland. The actual tax burden must nevertheless be assessed on a case-by-case basis, taking into account income, personal circumstances, the taxes applicable in both countries and whether the substitute tax regime is chosen.
What are the differences between the two issues?
The healthcare tax and the Omnibus Decree should not be confused.
The healthcare tax concerns a contribution provided for under Italian legislation for specific categories of cross-border workers. The main issues currently concern its implementation, the legal challenges and developments in regional measures.
The Omnibus Decree, on the other hand, concerns a tax election available to a specific category of workers. The issue reported for 2026 relates to the increase from 80% to 100% of Swiss withholding tax in Ticino for the workers concerned who choose this regime.
These are therefore two separate processes: in the first case, it is necessary to monitor the measures required to implement the contribution; in the second, it is essential to verify eligibility for the tax election and the effects of the taxation applied in Switzerland.
What should cross-border workers and employers check?
In a changing regulatory environment, a preliminary review can help avoid misjudgements and unexpected tax consequences. In particular, it is advisable to:
- Verify the worker’s tax status, distinguishing between old cross-border workers, new cross-border workers and those who may be covered by transitional regimes or specific provisions.
- Check potential eligibility for the Omnibus Decree regime, without assuming that the option is available to every cross-border worker.
- Review the withholding tax treatment applied in Ticino, especially if the Italian tax election is being considered or has already been made.
- Monitor official measures relating to the healthcare tax, distinguishing general legislative provisions from the measures required for their practical implementation.
- Keep tax and payroll documentation, so that the treatment applied can be reconstructed and the different options compared correctly.
Tax decisions should be based on the rules applicable to the individual situation and on up-to-date information, rather than solely on general news or interpretations that are still under discussion.
Why is an individual tax assessment important?
Cross-border taxation requires Italian and Swiss provisions, bilateral agreements and the taxpayer’s personal circumstances to be considered together.
The worker’s category, municipality of residence, date of commencement of employment in Switzerland and chosen tax regime may result in significant differences in the applicable tax treatment.
An individual assessment makes it possible to verify the relevant requirements, understand the consequences of the different options and identify issues requiring further analysis. It is particularly important when an interpretative or administrative change may affect the calculation of withholding tax or the overall tax outcome.
How can Fidav support you?
Tax matters involving Italy and Switzerland can raise questions and require a specific assessment. Understanding your own situation is the first step towards addressing these issues with greater confidence and peace of mind.
Do you have questions about your tax situation or would you like to explore these topics further?*
The Fidav team is available to listen to your concerns and assess possible solutions with you.
Write to us at info@fidav.ch: we will be happy to discuss your situation with you.
Let's talk
Does this topic concern your business too? Let's meet.
Half an hour of conversation does more than a thousand emails. Chat with us on WhatsApp or let's book a meeting: no commitment, no costs.