The Italian Revenue Agency’s Ruling No. 177/2026 clarifies an issue of particular relevance to individuals relocating from Switzerland to Italy.

An individual who is tax resident in Italy, holds both Italian and Swiss citizenship, and receives a pension arising from previous public-sector employment in Switzerland.

The principle established is clear: the pension remains taxable exclusively in Switzerland, even after the individual transfers their tax residence to Italy.

The rationale lies in Article 19(1) of the Italy–Switzerland Double Taxation Convention, which grants the paying State the right to tax public-sector pensions paid to individuals who are nationals of that State.

An important point is that Swiss citizenship need not be exclusive. Holding dual Italian and Swiss citizenship does not alter the tax treatment provided for under the Convention.

The position differs, however, for individuals who hold Italian citizenship only: in such cases, the Swiss public-sector pension is taxable exclusively in Italy pursuant to Article 18 of the Convention.

This is a further example of how, in international taxation, tax residence, citizenship and the nature of the pension must be considered together, with due regard always being given to the specific tax convention applicable.