Fourteen theses for practitioners, clients and policymakers

How the theses are meant

The following theses condense the argument of the book into propositions that can be tested against practice. They are addressed to three groups whose interests overlap without coinciding. Practitioners are the bankers, lawyers, fiduciaries, trustees, tax advisers and compliance officers who work in and with Lugano. Clients include Italian families, entrepreneurs, trading houses and the institutions that use the centre. Policymakers sit in the city, the canton and the Confederation, and in the professional associations that speak for the industry. Each thesis is followed by a short justification with a reference to the chapters on which it rests. The theses are the author's conclusions. Where they rest on assessments, as in the case of the scenarios to 2035, they share the uncertainty of those assessments.

The theses

● Lugano is a relational financial centre whose product is the competent crossing of a border. From the notarial credit of the Lombard periphery to the external asset manager agreement of today, the centre's value has lain in moving persons, goods, money and documents lawfully between two legal orders. Its institutions, from the fiduciary to the Lugano Convention, are instruments of that crossing (Chapters A.I, E.III and H.IV).

● The Italian client remains the core of the centre in every plausible future. All three scenarios of Chapter K.II assume that the Italian clientele remains the most important foreign market. Diversification towards other markets is desirable, but a strategy for Lugano that does not begin with Italy misreads both the history and the figures (Chapters E.I and K.II).

● Secrecy was a historical condition of Lugano's rise and is no longer a source of value. The combination of Italian exchange control and Article 47 of the Banking Act explains the boom of 1945 to 1975. Automatic exchange with Italy since 2018, group requests and the tax predicate offence since 2016 have removed the value of undeclared assets. Any business that still depends on them is a liability for the whole centre (Chapters D.I, D.II and E.II).

● Market access has become the binding constraint on the Lugano model. Italian law requires an authorized branch for investment services to retail clients and, from 11 January 2027, for deposits, loans and guarantees. Unauthorized activity is a criminal offence for the relationship manager. The Switzerland–EU package of 2026 contains no agreement on financial services. Every business plan in Lugano must therefore state on which legal basis it serves Italian residents (Chapters E.IV and K.I).¹

● Competence in two legal orders is the centre's distinctive asset and must be cultivated deliberately. Lugano's professionals read Swiss law in Italian and understand Italian law in its own terms. That skill is what Italian families need for succession, residence and structuring. It is not self-maintaining, because the share of Italian speakers is declining and machine translation reproduces false friends unless it is trained on the concepts of both orders (Chapters E.V, J.I and J.III).

● Substance is the single legal test that decides most cross-border structures. The margin of a trading house, the residence of a company, the exemption from Italian CFC rules, the residence of a relocated entrepreneur and the defence against a hidden permanent establishment all turn on where people work and decisions are taken. Advice that changes register entries without changing facts produces the most expensive outcome (Chapters F.II, F.III and H.II).

● Scandal has been the main engine of Swiss financial regulation, and Ticino has repeatedly supplied the scandal and the remedy. The crash of 1914 produced the State bank, Chiasso produced the due diligence agreement and the Pizza and Lebanon Connections produced the money laundering offence, drafted by a former Ticino prosecutor. The lesson for the industry is to anticipate rules by its own standards before the next case imposes them (Chapters C.IV, D.III and D.IV).

● The fiduciary and independent asset management sector is the most characteristic and the most vulnerable part of the centre. It grew out of the Italian clientele, was licensed first by Ticino in 1984 and passed under FINMA supervision in 2020. Its small firms now face rising fixed costs and an unresolved succession problem, and their exit can move assets out of the canton when clients are absorbed by banks booking elsewhere (Chapters E.III and K.II).

● Commodity trading gives Lugano a second pillar whose main risks are legal. The cluster's specialization in steel and metals and its links to Italian industry are real strengths. Sanctions, trade finance scarcity after 2020 and Italian tax scrutiny have shown that the conditions of its survival are documented supply chains, sanctions compliance under three regimes and real decision-making in Lugano (Chapters F.I, G.I and G.II).²

● Ticino's exposure to organized crime is structural and requires a permanent institutional answer. The border with the Italian region in which the 'Ndrangheta is most strongly established, the shared language and a dense network of fiduciaries and real estate businesses make the canton a front line. The extension of anti-money laundering duties to advisers since October 2026 closes a gap that Ticino cases had exposed (Chapters G.III and G.IV).

● Technology is an instrument of the centre and cannot replace its foundations. Plan ₿ brought visibility at low public cost, and Ticino's research institutions give it real capacities in artificial intelligence and computing. The legal frame for Kryptowerte und Digital Assets is federal and identical across Switzerland, while access to Italian clients is governed by European law. Technology will matter most where it lowers the cost of compliance and serves the existing client base (Chapters I.I to I.III).

● The Italian language is a federal asset that the Confederation has an interest in protecting. The equality of Italian in federal law, the Federal Criminal Court in Bellinzona and the Italian-speaking competence of Lugano serve Switzerland as a whole in its relations with Italy and its southern neighbours. The representation of Italian speakers in the federal administration and the teaching of Italian north of the Alps are therefore matters of national economic policy (Chapters J.I and J.II).

● The slow trends will decide Lugano's future more than any single political event. Demography, the generational change in Italian families, the succession of asset managers and automation determine most of the range of outcomes to 2035. Political events in Bern, Brussels and Rome shift the probabilities. A centre that responds well to the slow trends can reach niche excellence even without a breakthrough in market access (Chapter K.II).³

● The canton, the city, the industry and the Confederation must act together because none of them controls the outcome. Training, succession planning, specialization and stable taxation lie within Ticino's reach. Market access, capital rules and the relationship with the European Union are federal matters. Lugano's history shows that it has prospered when Swiss institutions and Italian demand moved in step, and that it has suffered when it relied on one without the other (Chapters C.IV, K.I and K.II).

Using the theses

The theses are meant to be used as a checklist for decisions. A bank that considers opening an Italian branch, an asset manager who plans his succession, a trading house that chooses its seat and a canton that revises its tax law can each test their plans against them. Several theses point in the same direction from different starting points. Theses 4, 6 and 9 all lead to the conclusion that Lugano's advantages are available only to those who perform real functions under the law of both states. Theses 5 and 12 lead to the conclusion that the Italian language must be maintained as professional competence and as federal policy at once. Theses 13 and 14 lead to the conclusion that the outcome to 2035 depends on many actors acting in the same direction over a long period. Taken together, they describe a financial centre whose future lies in the quality of its work, which every firm and authority in Ticino can influence.

Essentials. The theses reduce to three propositions. Lugano's value lies in the lawful crossing of the border with Italy, and that crossing now depends on competence, substance and market access. Its distinctive assets are its Italianspeaking professionals, its knowledge of two legal orders and Swiss institutional stability. Its future will be decided less by any single agreement than by the response of its firms and authorities to demography, succession and technology.

Notes

1. TUF, Art. 28, 29-ter and 166 (above); Directive (EU) 2024/1619 (above); Swiss Federal Council, press release of 25 February 2026 (above). ↩
2. Federal Council, press release of 28 February 2022 (above); BNN Bloomberg, 23 September 2020 (above). ↩
3. See Chapter K.II. The probabilities attached to the scenarios (about one half for niche excellence, three tenths for gradual erosion and one fifth for Lombard renewal) are the author's assessment. ↩

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.