A roadmap for clients with an Italian nexus

Mapping the structure

The first task in any Swiss-Italian mandate is to draw the structure as the authorities of both states will see it. The practitioner should list every legal entity, account, trust and holding of Kryptowerte und Digital Assets, and for each of them identify the legal owner, the beneficial owner under the TJPG and under Italian law, the controlling persons under the CRS and the tax residence of each person. The map should cover the past as well as the present, because the open tax years in Italy reach back several years and because the history of a structure determines whether the funds that flowed into it derive from a tax offence. Chapter E.II gives the Italian limitation periods and the checklist for legacy assets. The present roadmap concerns the current and future obligations.

Four constellations recur in Lugano practice. The first is the Italian resident who holds an account or a portfolio at a Ticino bank, directly or through a Swiss or foreign company. The second is the Italian resident who controls a Ticino operating or holding company, often a family business that moved part of its activity to Ticino, a case that Chapter H.II examines. The third is the Italian national resident in Ticino, who may have kept accounts, real estate or companies in Italy. The fourth is the trust or foundation with an Italian settlor or Italian beneficiaries and a Ticino trustee or council member. Each constellation triggers different registers and reports.

Constellation Swiss side Italian side Italian resident, Lugano CRS report to Italy Quadro RW, IVAFE account Italian resident controls Ticino TJPG register; CRS if Quadro RW, CFC test SA passive Ticino resident, Italian assets Wealth tax return Register if Italian company Trust with Ticino trustee TJPG trust duties; CRS Quadro RW; Italian register Kryptowerte und Digital Assets CARF from 2027 at the Quadro RW; 2 per earliest mille tax

Source: author's synthesis of the rules discussed in this chapter.

Registers and reports: the sequence

The practitioner must then establish the order in which the various duties arise, because they are not synchronized. The Swiss transparency register requires first reports by 1 January, 1 February, 1 March or 1 April 2027 depending on the category of company, and by 1 October 2028 for beneficial owners already entered in the commercial register.¹ The Italian register of beneficial owners will require communications once the ministerial decree under Legislative Decree No. 122/2026 is adopted, which had not happened by the end of September 2026.² The Italian income tax return, with the quadro RW, must be filed each autumn for the previous year, and the Swiss bank reports the year-end balance under the CRS by June, for transmission to Italy by the end of September.

The CARF obligations will start for Swiss service providers with the activation of the exchange, at the earliest on 1 January 2027, while Italian and other EU providers have collected data since 1 January 2026 under DAC8.³ FATCA reporting by Swiss institutions will move to the Model 1 channel on 1 January 2028. Advisers who form or manage non-operative companies had to apply for membership of a self-regulatory organization by 1 December 2026.

Date Event 1 October 2026 TJPG and revised AMLA in force 1 December 2026 Advisers' SRO applications due 1 January 2027 Earliest CARF activation in Switzerland 1 January–1 April 2027 First TJPG reports by category 30 June 2027 First Italian DAC8 reports 1 January 2028 FATCA Model 1 in force 1 October 2028 Deadline for entities in commercial register

Sources: as cited in the notes to this section.⁴

Notes

1. Grant Thornton (above); Homburger (above). ↩
2. ItaliaOggi, 23 September 2026 (above). ↩
3. SIF, FAQ zum AIA über Kryptowerte (Update) (above); Directive (EU) 2023/2226 (above); KPMG, Tax News Flash, 13 February 2026 (above), on FATCA; Landtwing Leupi (above), on the deadline of 1 December 2026. ↩
4. law.ch, June 2026 (above); Landtwing Leupi (above); SIF, FAQ (above); Grant Thornton (above); PartitaIVA.it (above); KPMG (above); Homburger (above). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.