Italy Tax Agency Clarifies Residency, Taxation of Employment Income Under DTA With Switzerland

The Italian Revenue Agency July 4 issued Letter No. 370/2023, clarifying rules on tax residency and employment income under the 1976 DTA with Switzerland. The taxpayer moved to Switzerland from Italy on May 31 of the specified tax year, and earned income in both countries in the same tax year. The taxpayer sought clarification as to whether the income earned in Switzerland from June 1 onwards was subject to taxation in Italy or Switzerland. The taxpayer also inquired as to whether the income earned in the following year in Switzerland could be taxed there exclusively. The Tax Agency clarified that: ...