Italian families as clients of the Lugano centre
From the undeclared deposit to the declared plan
The modern Lugano private banking market was built on Italian deposits, many of them undeclared. Chapter D.II described the cross-border couriers, the numbered accounts and the fiduciary companies of the post-war decades. Chapter E.II has traced the end of that model through the Italian tax amnesties of 2001 to 2009, the voluntary disclosure programme of 2014 and 2015 and the automatic exchange of financial account information with Italy, which produced its first data for 2017. When the regularization was complete, a large share of the Italian assets that had been held in Ticino had either been repatriated or declared to the Italian tax authorities while remaining in Switzerland. The client relationship that survived this process is of a different kind. Since a declared account in Lugano no longer offers protection against the Italian tax authorities, its value to the family must come from other sources. These include the quality of the service, the stability of the Swiss franc and of Swiss institutions, the convenience of a financial centre one hour from Milan and the legal expertise available in Ticino for questions that cross the border.
Among those questions, succession and residence have moved to the centre. A large part of the Italian wealth that is managed in Lugano belongs to entrepreneurs of the post-war generation from Lombardy, Piedmont, Veneto and Emilia-Romagna, whose companies are now passing, or have recently passed, to their children. The transfer of a family business raises questions of company law, forced heirship, inheritance tax and often residence. One of the heirs may already live abroad, or the founder may consider moving to Switzerland to retire. Each of these questions has an Italian and a Swiss dimension, whose answer frequently depends on how the two legal orders interact.
The Italian presence in Ticino
The Italian population of Ticino gives this market its physical basis. At the end of 2024 the canton had 358,903 permanent residents, of whom 105,542 or 29.4 per cent were foreign nationals. Italian citizens formed by far the largest group, with 64,240 persons, or 60.9 per cent of all foreign residents.1 To these must be added a large number of Swiss citizens with Italian roots or dual nationality and the cross-border commuters (frontalieri) who live in Italy and work in Ticino, whose taxation is examined in Chapter H.I. For the wealth adviser the relevant group is smaller. It consists of Italian families who have moved their residence to Ticino, Italian families who keep their residence in Italy but hold assets, companies or real estate in Switzerland, and mixed families in which some members live on each side of the border.
The legal position of each of these groups differs. An Italian national domiciled in Lugano is subject to Swiss tax law and, in principle, to Swiss succession law. The Italian tax authorities may nevertheless claim him or her as an Italian resident if the move was incomplete. Italian inheritance tax applies to Italian assets in any event. An Italian resident with a Lugano account is fully taxable in Italy and his or her succession is governed by Italian law unless a valid choice of another law has been made. A mixed family must coordinate two inheritance taxes, two systems of forced heirship and two sets of reporting obligations. Advice that ignores one of the two legal orders is incomplete and can be dangerous.
Notes
- Ufficio di statistica del Cantone Ticino (USTAT), "La popolazione cresce e invecchia", Notiziario statistico 2025-31, 11 September 2025, https://www3.ti.ch/DFE/DR/USTAT/allegati/news/254778ns_2025-31.pdf (consulted 5 October 2026). ↩
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.