Since autumn 2023, the Italian Revenue Agency has initiated intensive inspections of Italian taxpayers, owners or employees of Swiss limited liability companies (Sagl), beneficiaries of cross-border tax status whose income from employment is exclusively taxable in Switzerland. This inspection effort, far from abating, is actually intensifying, while the first decisions of the Tax Courts (CGT) repeatedly confirm the approach adopted by the Italian tax authorities. In this context, the need to identify the best protection path for the taxpayers involved becomes urgent: is it more appropriate to resort to tax assessment by agreement or to initiate tax litigation directly? Given the cross-border nature of these cases, it is also essential to understand how any agreement reached in Italy will be assessed in Switzerland by the Canton of Ticino's Tax Division and what consequences it may have on the taxpayer's overall tax position. To make informed decisions, it is essential to examine the rationale expressed by the CGT in their most recent rulings, thus identifying the most critical aspects of the interpretation supported by both the Guardia di Finanza and the Revenue Agency, with particular reference to the provisions of the Double Taxation Agreement between Italy and Switzerland. The webinar will also provide an overview of additional cases, whether or not similar to audits involving cross-border workers and limited liability companies, including those involving sole proprietorships. The webinar organized by the Tax & Legal Competence Center of SUPSI is dedicated to these topics.

Program and Speakers
Assessment by Agreement and Its Consequences: Consideration in Taxpayer Choice
Gianluigi Bizioli
Full Professor of Tax Law and International and EU Tax Law at the University of Bergamo, Of Counsel, PwC Tax and Legal Services, Milan

Approach of the Canton of Ticino's Tax Division to the Position Defined by Agreement
Giordano Macchi
Dipl. Math. ETH, Bachelor of Science in Economics, Master of Advanced Studies SUPSI in Tax Law, Director of the Canton of Ticino Tax Division

Critical Analysis of First-Instance Decisions: External Management and Employment Relationships
Guido Beltrame
Chartered Accountant, BTWM & Partners, Milan, Trustee, Belrevicom Sagl, Mendrisio

Interpretation and Application of Convention Rules in the Case of Cross-Border Workers and Limited Liability Companies
Francesca Amaddeo
Lawyer, Dr. iur., Lecturer-Researcher at the SUPSI Tax and Legal Competence Center, Of Counsel, Belluzzo International Partners, Lugano

Cross-Border Workers and Sole Proprietorships: Tax Treatment and Possible Audits by the Italian Tax Authority
Marco Calcagno
Chartered Accountant, TEP, GISEV Family Office, Lugano

Cost
CHF 350.-
CHF 50.- discount for members of partner organizations

Registration
https://bit.ly/webinar-05-02-2026

Registration deadline
Tuesday, February 3, 2026