Research guide

Como Property: The 2023 Agreement Rewrote Who Pays Tax

Law 83/2023 brought the new Italy-Switzerland commuter agreement into force on 17 July 2023. Where you live decides whether it applies to you at all.

Como Property: The 2023 Agreement Rewrote Who Pays Tax

Quick answer: A large share of the housing demand around Como comes from people who earn francs across the frontier and spend euro at home. The tax basis of that arrangement changed on 17 July 2023, and whether it applies to a given household depends on when they started and on which comune they live in.

Property writing about Como is about villas. The market that actually determines prices in most of the province is about commuting, and the rules that govern it were rewritten three years ago. For a buyer looking at ordinary housing anywhere near the frontier, that change is more consequential than anything happening on the lake.

What changed and when

The agreement between Italy and Switzerland on the taxation of cross-border workers was signed on 23 December 2020, ratified by Italy through law 83 of 2023, and entered into force on 17 July 2023.

Its central feature is a division of the population into two groups by date.

GroupDefinitionTax position
New cross-border workersAcquired the status after 17 July 2023Taxed in both states
Existing cross-border workersWorked as employees in Switzerland between 31 December 2018 and 17 July 2023Taxed only in Switzerland, until retirement

For the new group, tax is withheld at source in the canton of work at rates equal to 80% of the ordinary ones, and Italian income tax is then charged in Italy with relief for the Swiss tax paid. For the existing group, the previous arrangement continues.

That produces the situation that defines the local labour market: two people doing the same job for the same employer, living on the same street, on different net incomes because one started before a date and one after.

Why this is a property question

Because eligibility depends on where you live. The status attaches to residence in a comune whose territory falls, wholly or partly, within the border strip running to 20 kilometres from the frontier. A household whose income depends on that status cannot simply buy the house they prefer; they have to buy inside the line.

The consequences for the local market are visible in prices and are frequently misread by outside buyers.

  • Comuni inside the strip carry a demand premium that local Italian salaries alone would not support
  • The premium is not uniform: it reflects commuting time to specific Swiss workplaces as well as the strip boundary
  • A property just outside the strip serves a different and smaller buyer pool, whatever its qualities
  • Rental demand in these comuni is driven by the same population, which makes it more stable than tourist demand and more exposed to cross-border policy

For a foreign investor, the practical instruction is to establish, for any specific comune, whether it falls within the strip, and to treat that as a hard input rather than an approximation. The information is definite and obtainable.

What the Italian side provides

The Italian implementing provisions include an exempt band on cross-border employment income of €10,000, together with treatment of family allowances paid by the social security institution of the state where the work is performed.

Those provisions reduce the impact of concurrent taxation without eliminating it. For any individual household the net effect depends on the canton, the gross salary, the family situation and which of the two groups they fall into, which is why a competent local accountant is worth more than any general statement in an article.

What can be said generally is that the direction is settled. Households acquiring the status now face a higher combined burden than households that acquired it before July 2023, and that gap is a permanent feature of the market rather than a transition.

What a franc income does to a purchase

Earning in one currency and buying in another introduces a set of practical issues that Italian lenders handle in their own ways rather than uniformly.

  1. Affordability assessment has to account for exchange rate movement, and lenders apply their own haircuts
  2. Documentation of foreign employment and foreign payslips takes longer to assemble and to verify
  3. Some lenders are considerably more comfortable with this profile than others, largely because of where they operate
  4. The mortgage will be in euro while the income is in francs, which leaves the borrower carrying the currency risk
  5. Anti-money-laundering documentation on funds arriving from a non-EU state is more detailed

None of this prevents borrowing and all of it is smoother when raised at the start. A buyer who discovers at the valuation stage that their lender is uncomfortable with franc income has lost weeks.

For Swiss nationals buying in Italy as investors rather than commuters, the position is a different one again and is set out in the guide for Swiss buyers.

What the change did to the local market

Border property markets are shaped by net income rather than gross, and a change to the tax basis of that income works through prices with a lag.

The immediate effect was on the marginal buyer. A household considering a move to a border comune after July 2023 faces a different net income from an equivalent household that moved in 2019, and that changes what they can borrow and what they will pay. Since existing workers keep the old treatment until retirement, the two groups coexist and will do for decades, which slows the adjustment rather than preventing it.

The second effect is on the composition of demand. A larger share of the local pool is now people whose combined tax position depends on Italian rates, which makes them more sensitive to Italian property taxation, to running costs and to the second-home charge. Owners letting to this group should expect tenants to pay closer attention to charges than they used to.

The third effect is on the boundary itself. When the tax status attaches to residence in a defined strip, the strip becomes a value line rather than an administrative one. Buyers should therefore be sceptical of comparisons between two properties that appear equivalent but sit on opposite sides of it.

  • Establish which group a prospective tenant belongs to, since it determines their disposable income
  • Expect the demand premium inside the strip to persist while the two groups coexist
  • Treat any advice written before July 2023 as describing a regime that no longer applies to new arrivals

A model for a border comune flat

Take a flat inside the strip: 79 square metres with parking, bought at €228,000 all in, let unfurnished to a commuting household at €790 a month.

LineAmount
Annual rent€9,480
Condominium charges borne by the owner€710
Vacancy allowance, 3 weeks a year€545
Gross yield on the all-in price4.2%

The figures are illustrative. What the model is meant to show is that this is a plain residential letting business with an unusual demand driver behind it: not tourism, not students, but employment across an international frontier whose tax treatment is set by treaty and can change again. An owner underwriting it should therefore be tracking a bilateral agreement rather than a local rental index, which is an unusual thing to ask of a residential landlord and is the price of the demand premium.

Two markets that share a lake

The province contains two property markets that have very little to do with each other, and most confusion here comes from treating them as one.

The frontier market is ordinary housing in border comuni, bought by households with Swiss employment, priced on commuting time and on the tax status described above. It is deep, transactional and responsive to policy.

The lake market is second homes and villas, bought by people whose income comes from elsewhere entirely, priced on setting, frontage and scarcity. It is thin, slow and responsive to international sentiment rather than to Italian or Swiss tax rules.

  • A comparison of yields between the two is close to meaningless, because the assets serve different purposes
  • The frontier market’s risk is policy; the lake market’s risk is liquidity
  • Only the frontier market has a demand base that lives here year round
  • Bellagio sits firmly in the second market and carries its own specific issues around lakeside rights

For buyers weighing the lake against other Italian options, the Garda and Como comparison, the Tuscany and Como comparison and the Liguria and Como comparison each set out a different version of that choice. For urban alternatives within reach, Milan’s Navigli is the obvious contrast.

Where the demand actually sits

Commuting geography, not scenery, decides which comuni carry the premium, and it is finer grained than a 20 km radius suggests.

The crossing points are the bottleneck. A comune close to a busy crossing with a queue at seven in the morning can be a worse commute than one further away on a quieter route, and residents know exactly which is which. The rail link matters too, since a household with a station within walking distance avoids the crossing queue entirely and can run one car instead of two.

The Swiss workplace matters as well. Employment concentrates in specific cantonal centres, and a comune well placed for one is not necessarily well placed for another. A buyer letting to this market should know which workplaces their address serves.

  • Test the actual commute at the actual hour, not the mapping application’s estimate
  • Prefer addresses with a rail option, which insulates a tenant from road conditions
  • Ask a local agent which employers the street’s residents work for
  • Remember that the strip boundary is a legal line and the commute is a practical one, and both matter

What happens on resale

The buyer pool for a house inside the strip is largely the same population that occupies it: households with cross-border employment. That is a real pool and it is not a large one, and it is sensitive to the same policy the current owner is.

Two implications follow for anyone underwriting an exit. A change in the cross-border regime affects the value and the liquidity of the asset simultaneously, since it removes buyers rather than merely reducing what they will pay. And the property’s appeal to a buyer without cross-border employment is materially lower, because they are paying a premium for a status they cannot use.

Diligence points specific to the province

Assemble the file described in the due diligence guide, then answer three questions that only a frontier purchase raises.

Confirm the comune’s position relative to the border strip, in writing, if the purchase depends on it.

Establish commuting reality rather than map distance. Crossing points have queues, and a comune 12 kilometres from the frontier by road can be 45 min from a workplace at seven in the morning. Local buyers price this precisely and remote buyers do not.

Check the building’s heating and energy performance. Winter here is real, the housing stock includes a great deal of poorly insulated post-war construction, and running costs are a live part of what a commuting household compares.

Modelling rental returns in the frontier comuni is a different exercise from modelling them on the lake, and the rental yield guide sets out the method for both. The input that matters most here is that tenant demand comes from employment across a border, and that the terms of that employment were changed by statute in 2023.

Property currently on our books around the lake, with asking prices and what first-line actually means, sits on property for sale on Lake Como.

Frequently Asked Questions

The agreement between Italy and Switzerland of 23 December 2020, ratified by law 83 of 2023 and in force from 17 July 2023. It replaced the previous arrangement under which cross-border workers resident in the Italian border area were taxed only in Switzerland, and it distinguishes between those who held the status before that date and those who acquired it after.

In both states. Tax is withheld at source in the canton of work at rates set at 80% of the ordinary ones, and Italian income tax is then due in Italy with relief for the Swiss tax. That is a materially different net position from the previous regime, and it applies to anyone acquiring the status after 17 July 2023.

Broadly, those who worked as employees in Switzerland between 31 December 2018 and 17 July 2023. They continue to be taxed exclusively in Switzerland until retirement, which means two neighbours doing the same job across the same border can be on entirely different tax footings depending on when they started.

Because the status depends on residence in a comune within the border strip defined by the agreement, which runs to 20 kilometres from the frontier. A house on the wrong side of that line does not confer the status, and for a household whose income depends on it, that boundary is a more important property fact than the view.

The Italian rules raise the exempt band on cross-border employment income to €10,000, alongside treatment of family allowances paid by the social security institution of the state of work. Those provisions soften the effect of concurrent taxation without removing it, and the arithmetic should be run for the individual case rather than assumed.

It changes how an Italian lender assesses the file. Income in a foreign currency introduces exchange risk into the affordability calculation, and lenders respond with their own policies rather than with a single rule. A buyer in this position should establish the lender's approach before making an offer rather than after.

It affects the depth of local demand. Border comuni have long been supported by households earning in francs and spending in euro, which is a large part of why prices near the frontier sit above what local Italian salaries would support. A change in the tax treatment of that income is a change in that support.

No, and the two markets barely overlap. The frontier commuter market is about ordinary housing in border comuni for people who work in Switzerland. The lake villa market is about second homes for buyers whose income comes from somewhere else entirely. Confusing the two produces bad comparisons in both directions.

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