Niches, compliance and the hinterland: Parts F to H

The trading house as second pillar

Part F described a second pillar that the public image of Lugano as a banking town tends to hide. In 2024 Swiss commodity trading produced a gross value added of CHF 19.2 billion. Geneva generated CHF 11.2 billion of it and Zug CHF 5.2 billion, while Ticino, with CHF 685 million or 3.6 per cent, came fourth behind Vaud.¹ Measured by firms, the canton carries more weight: the Federal Statistical Office counted 117 trading firms in Ticino in 2021, about one in eight Swiss commodity traders.² Chapter F.I traced the cluster from the forwarding houses of Chiasso and the Italian steel and coal traders of the 1980s to the trading arms of Russian and Ukrainian steel producers after 1991, organized since 2010 in the Lugano Commodity Trading Association.³ Steel and other metals account for about 60 per cent of its employment. The war of 2022 hit Lugano harder than any other Swiss hub, because Swiss law now forbids persons in Switzerland to buy the Russian products that several Luganese houses had been created to sell.

Chapter F.II analysed the law of these houses. The Federal Act on Tax Reform and AHV Financing (TRAF) abolished the mixed company and principal regimes from 1 January 2020. Ticino lowered its cantonal profit rate in two steps to 5.5 per cent in 2025, which brought the effective rate in the cantonal capital to 16.05 per cent and in Lugano to about 15.5 per cent.⁴ The OECD minimum tax sets a floor of 15 per cent for large groups. On the Italian side, the controlled foreign company rules of Article 167 TUIR and the corporate residence rules of Article 73 TUIR, both reformed by Legislative Decree No. 209 of 2023, decide whether a Lugano company owned or managed from Italy is taxed in Switzerland, attributed to its Italian owners or treated as Italian itself.⁵ The chapter's conclusion was that substance links all these strands, because the functions that justify the trader's margin are the same facts that protect it against the Italian rules.

Chapter F.III extended the same analysis to the distribution economy. The "Fashion Valley" of the Mendrisiotto and the Luganese was estimated in 2013 to employ about 8,000 persons and to pay about CHF 90 million of taxes a year.⁶ In May 2019 Kering paid the Italian tax authorities EUR 1.25 billion to settle claims concerning a hidden permanent establishment of its Swiss subsidiary Luxury Goods International (LGI) in Italy, after which the group moved its logistics to Trecate.⁷ The Fashion Valley, the trading houses and the shipping desks of Lugano form one economic model: a Swiss company buys, holds and resells goods produced and consumed elsewhere, earning the profit of those activities only if it performs them in Switzerland.

Notes

Bundesamt für Statistik (BFS), "Die Wertschöpfung des Rohstoffhandels belief sich 2024 auf 19,2 Milliarden Franken", press release, Neuchâtel, 18 November 2025, https://dam-api.bfs.admin.ch/hub/api/dam/assets/36221190/master (Geneva CHF 11,247 million or 58.4 per cent; Zug CHF 5,200 million or 27.0 per cent; Vaud CHF 1,241 million or 6.5 per cent; Ticino CHF 685 million or 3.6 per cent), as cited in Chapter F.I. ↩
BFS, Statistik der Rohstoffhändler (NMP), tables 2017–2021 and cluster 2022, published 25 August 2023, https://dam-api.bfs.admin.ch/hub/api/dam/assets/26645739/master (Ticino 2021: 117 firms, 12.1 per cent of the Swiss total). ↩
Lugano Commodity Trading Association (LCTA), "Chi siamo", https://www.lcta.ch/chi-siamo/ (founded 2010 as a non-profit association in Lugano). See Chapter F.I. ↩
SWI swissinfo.ch, "Swiss corporate tax rates edge down slightly", 21 May 2025, https://www.swissinfo.ch/eng/various/swiss-corporate-tax-rates-edge-down-slightly/89374335, reporting the KPMG Swiss Tax Report 2025, as cited in Chapter F.II for the effective rate of 16.05 per cent in the cantonal capital. The rate of about 15.5 per cent in Lugano is the author's calculation in Chapter F.II (federal tax 8.5 per cent, cantonal tax 5.5 per cent × 96 per cent, communal tax 5.5 per cent × 82–85 per cent, the multiplier for legal entities). ↩
TUIR, Art. 73 para. 3, as amended by Legislative Decree No. 209 of 27 December 2023, text at Brocardi.it, https://brocardi.it/testo-unico-imposte-redditi/titolo-ii/capo-i/art73.html. On Art. 167 TUIR see Chapter F.II. ↩
Tio.ch, "La Fashion Valley è arrivata alla fine?" (7 October 2018, updated 22 May 2019), https://www.tio.ch/ticino/focus/1310700/la-fashion-valley-e-arrivata-alla-fine. The figures are press estimates and not official statistics. ↩
Il Fatto Quotidiano, "Kering pagherà 1,25 miliardi al fisco dopo indagine di Gdf e Procura di Milano" (9 May 2019), https://www.ilfattoquotidiano.it/2019/05/09/kering-paghera-125-miliardi-al-fisco-dopo-indagine-di-gdf-e-procura-di-milano/5167127/. See Chapter F.III on the move to Trecate. ↩

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 October 2026.

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Niches, compliance and the hinterland: Parts F to H

The trading house as second pillar

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