CAMPIONE D’ITALIA – AN ITALIAN TAX HAVEN IN THE HEART OF SWITZERLAND…… WHY SMART HIGH NET WORTH INDIVIDUALS ARE CHOOSING ITALY OVER MONACO, SAVING MILLIONS.

The Italian tax haven of “Campione d’Italia” is a part of the Republic of Italy, known as an enclave”, with some very unique tax concessions, allowing HNWI’s to transfer to Switzerland without really being there. The specific tax rules allow individuals to live almost tax free and without immigration problems, usually associated with entry into and residency of Switzerland

It’s a place where HNWI’S can have their cake and eat it, since it’s a Rolls Royce at the price of a FIAT!

Climate

The “Comune di Campione,” so called by Italians, lies on the shores of Lake Lugano, is completely surrounded by Switzerland. It lies approximately 300m above sea level and boasts a mild sub-alpine, almost Mediterranean climate. The average temperature ranges from approximately 25 degrees in the coldest months (December/January) to approximately 85 degrees in the warmest month (July).

There are frontier controls and complete freedom of travel. It lies in the southern Swiss canton of Ticino, about 16 miles north of the Italian border. Campione is a warm “village|” to live in, located in the heart of one of the best Swiss and nearby Italian tourist areas. This area is proud of its lakes, winter sports, and the cultural activities of Milan, which is about an hour away.

General

It consists of 1.7 sq. kilometres inside Switzerland, having about 3,000 inhabitants, about 1,000 of whom are foreigners. The official currency is the Swiss Franc, however the Euro is accepted. The postal service and telephone system and even the Licence plates are Swiss, as is the broadband. It is a short drive to Austria, Liechtenstein, Germany or France,

All banking is Swiss and so the HNWI can benefit from financial privacy, albeit that Italy has recently signed an information treaty with Switzerland.

A well-established Casino generates substantial income, which is one the main reasons why the residents of Campione benefit from some very particular tax concessions.

Campione benefits from a high level of security, 24 / 7, enforced by the local Carabinieri.

Taxation

Campione is a viable alternative for any HNWI wanting a tax haven residence, but who doesn’t want to spend the high prices of Monaco.

Campione’s residents, in sharp contrast with foreigners in Switzerland, are not subject to the double taxation treaties with most of Western Europe. Profits arising from bank deposits, shares and bonds, real estate and other transactions from a Swiss or international source are not registered for tax purposes for Campione residents, as long as they are channelled through Swiss Banks.

For a non-Italians who live in Campione, income tax is essentially, zero. There is no property tax if property is held in personal name. There is a very low property tax otherwise.

Campione’s tax benefits only apply to private individuals resident in Campione and not companies domiciled or managed from there. All tax breaks in this Comune are for residents only. Corporations are taxed at the usual Italian rates.

VAT is not payable in campione, which is why it is an attractive destination for company formations.

Residents of Campione do not pay the full Italian income tax.

Based on a special provision in Italian law, the first CHF 200,000 of income is changed into euros, the official currency in Italy, at a special exchange rate. This produces a lower taxable income and consequently a lower tax rate is applied.

However this only applies on the first CHF 200,000 of income.

Besides this special concession, the usual Italian tax laws and tax rates apply. As in Italy, there are no inheritance or gift taxes, and income from interest of foreign bonds paid through an Italian bank is taxed at a special, reduced rate of 12.5% only.

There are no gift or inheritance taxes.

Since real estate is scarce, prices are quite high, although if you contact a local they can usually help.

Foreigners residing in Campione need to pay taxes on their worldwide income to the Italian tax authorities.

Non-EU and foreign nationals, will need a Swiss visa to enter this territory.

Becoming tax Resident in Campione

All you need to become an official resident is to rent or buy property here, although formal registration is required. There is very rarely an opportunity to rent.

Police clearance from the Italian authorities as well as approval by the local Campione authorities is also required. This means that your passport must allow you to enter Switzerland without a visa otherwise you will have to apply for a Swiss visa beforehand. A passport is required for entry into Switzerland but a visa is not required for non EEA citizens for stays of up to 90 days.

Residence permits are issued by Italian authorities, BUT access to the territory of Campione is governed by Swiss visa regulations. Residents in Campione can later obtain an Italian identity card.

You will be eligible to apply for Italian citizenship after 10 years of legal residence.

A residence permit in Campione d’Italia can be obtained by forming a company along with renting or buying a property.

A company with the minimum capital requirement of EUR 10’000, to incorporate S.R.L “Società a responsabilità limitata” (or Limited Liability Company) with 2 associates, 1 director, is needed.

The other charges such as agent fee, incorporation fee, nominee director are extra.  A personal visit to campione is a must and usually asked to complete the formalities.

Besides this there are costs fof EUR 6’000 for notarial deed etc. Annual running costs of the company are approximately CHF 10’000 annually.

Since real estate is limited and in high demand, prices are high. Living in Campione is very expensive. A very small townhouse may cost £500,000 or more. Foreigners can buy real estate without restrictions, unlike in Switzerland. Real estate prices are well above those in surrounding Ticino and agent fees are another 3%.

A secondary option is to rent on a 4yr contract. Monthly rentals are approximately CHF 2000 to CHF 3000. Purchase of a property is the only option if rented accommodation is unavailable.

This small market is served by a few local real estate agents, some of whom operate without a license. A foreign buyer should exercise great caution and should be represented by a competent lawyer.

Business

Corporations registered in Campione have advantages over Swiss companies. They use Swiss banking facilities and have a mailing address that appears to be Swiss, while escaping Switzerland’s income and withholding taxes. Corporations are governed by Italian corporate law and can be formed with a minimum capitalization of about US$1,000.

Corporations can be owned and controlled entirely by foreigners, something which Swiss law limits somewhat. Corporate registrations are usually handled by Italian lawyers in nearby Milan, and fees are modest. As part of Italy, EU business regulations do apply to Campione businesses, as do Italian corporate taxes, which can be high.

Government

Campione is governed by Italian law. It does not belong the EU [according to Article 7 of Italian Decree 633/72 and is not subject to VAT on goods and services into and out of Switzerland.

Medical Care

Adequate medical care may be found in the nearby city of Lugano. For excellent medical care, residents may choose to drive to Zurich or Geneva.

For further information about taking advantage of Campione’s tax laws and benefits, contact

Stefano Lucatello head of Offshore taxation at:

Kobalt Law LLP

Email: stefanol@kobaltlaw.co.uk

Call: +44(0) 207 739 1700

Web: www.kobaltlaw.co.uk

Recent News Articles

CAMPIONE D’ITALIA – AN ITALIAN TAX HAVEN IN THE HEART OF SWITZERLAND…… WHY SMART HIGH NET WORTH INDIVIDUALS ARE CHOOSING ITALY OVER MONACO, SAVING MILLIONS.

The Italian tax haven of “Campione d’Italia” is a part of the Republic of Italy, known as an enclave”, with some very unique tax concessions, allowing HNWI’s to transfer to Switzerland without really being there. The specific tax rules allow … more…

What is Air B and B doing to the world we live in?

I understand why it was created and how it works, but it can cause neighbours of such ‘mostly illegal ” activities in leasehold premises, great inconvenience. Not only is it disconcerting to have regular changes of people next door, many … more…

TURKEY…. A GREAT PLACE TO INVEST….OR A TIME BOMB WAITING TO EXPLODE?

I was interested to read a fellow commentator’s opinions on Turkey, especially his statement that…” Turkey will make an appealing investment proposition”. Turkey has always been a “femme fatale” for English tourists and buyers. Its beautiful waters and cities, have always drawn … more…

Brexit…..Will it ever happen and what it means for you………….

The UK’s vote to leave the European Union will lead to the biggest split in history – with the world’s 5th largest economy (the UK) exiting the world’s largest economic grouping (the EU). The uncertainty of how and when Brexit … more…

How to enforce EU judgments: European Enforcement Orders and Brexit

The EU ensures that judgments obtained in one EU country can be recognised and enforced in any other EU country. General rules for recognition of judgments Once you have obtained a judgment in your favour, that judgment must be recognised in … more…

Latest Kobalt Law Tweet

Latest Kobalt Law Client Testimonials

I would definitely recommend your services to anyone looking for assistance in Turkish law

I want to thank you for the legal work you undertook for me in selling/transferring the title deeds for my apartments in Turkey. The process was complicated but your hard work and perseverance paid off and I was able to … more…

Visit Testimonials Page