The Characterization of the Healthcare Levy on Cross-Border Workers in Italy and Switzerland: Treaty, Tax and Comparative Aspects

This note examines the proposed healthcare levy on Italian cross-border workers employed in Switzerland and its interaction with the Italy-Switzerland Income and Capital Tax Treaty (1976). It analyses whether the levy should be classified as a tax covered by the treaty or as a social security contribution, assessing the consequences for double taxation relief and taxpayers’ rights. The note also considers the relevant treaty provisions, domestic legislation and principles of international tax law, highlighting the legal and practical implications of the proposed measure.