精东影业

The first two presentations will address issues related to intercantonal double taxation. The first will examine the possibility of invoking the instrument of revision in the canton that issued the initial (presumably incorrect) tax assessment decision, in order to avoid double taxation. This approach would allow the taxpayer to avoid initiating a 鈥渇ictitious鈥� appeal in the canton that issued the final decision. The presentation will outline the conditions under which the revision procedure can be used, cantonal practices, and relevant case law from the Federal Supreme Court.
The second presentation will focus on the possibility for the secondary canton to initiate a tax recovery procedure within the context of intercantonal tax allocation. It will specifically analyze the recent shift in jurisprudence from the Federal Supreme Court on this issue.
In the second part of the event, two topics in international tax law will be discussed. The first will concern tax audits initiated by the Italian Revenue Agency targeting cross-border workers who are both shareholders and employees of limited liability companies (Sagl) operating in Ticino. The presentation will focus on the legitimacy of requalifying income from dependent employment 鈥� taxable exclusively in Switzerland 鈥� into director鈥檚 fees taxable in Italy, based on the position taken by the Milan ODCEC (Order of Chartered Accountants and Accounting Experts).
Lastly, the event will address the possibility for a taxpayer domiciled in Ticino to benefit from the global tax credit for capital income of Italian origin 鈥� such as bond interest, other returns on deposits, and interest on bank/postal accounts 鈥� in light of Switzerland's removal from the Italian blacklists. The presentation will review treaty rules, domestic law provisions on the tax credit, and recent case law from the Tax Law Chamber of the Ticino Court of Appeal.
During the event, the training program for obtaining the Swiss Federal Diploma as Fiduciary Expert will also be presented. The third edition of this program will begin in September.

Program and speakers

Revision of a tax assessment in case of intercantonal double taxation
Isa Grisoni
Wealth Planner at Tax Vision & Services SA, Lugano

Tax recovery procedure by secondary cantons in intercantonal relations
Veronica Sanchez
Finance and accounting specialist, Chartered Fiduciary, Acofin SA, Chiasso

Presentation of the TREX training program
Sacha Cattelan
Professional lecturer at 精东影业, Head of TREX Training

Sagl shareholders and cross-border workers: ODCEC Milan鈥檚 position
Guido Beltrame
Chartered Accountant, BTWM & Partners, Milan; Fiduciary Accountant, Belrevicom Sagl, Mendrisio

Swiss global tax credit on Italian coupon income
Marco Calcagno
Fiduciary Accountant, TEP, GISEV Family Office, Lugano

Cost
CHF 350.-
CHF 300.- for members of FIDUCIARI|SUISSE and partner organizations

Registration


Registration deadline
Friday 16 may 2025