For anyone buying property in Italy as a foreigner, the timing has rarely been better. Switzerland has just proposed significant restrictions on foreign property ownership — and the contrast with Italy’s open, incentive-driven approach has never been sharper.
Italy Left It Open.
Switzerland has just moved to restrict foreign property ownership. Italy imposes no such restrictions — and actively incentivises purchase as a primary residence. For internationally mobile individuals weighing their options, the direction of travel matters as much as the current position. And there is a third option — the frontalieri — that most people have never heard of.
Last week we wrote about the prima casa regime — Italy's primary residence tax benefit — and how, from January 2025, buyers who already own a property purchased under prima casa rules now have 24 months (up from 12) to sell it when purchasing a new primary residence. That single extension makes the planning window considerably more manageable, and the difference between qualifying and not qualifying for the 2% registration tax can run to €40,000 or more on a single purchase.
This week, a story broke just north of the border that makes the Italian picture considerably more interesting by contrast.
The Swiss government has proposed tightening the Lex Koller law — the federal legislation governing foreign property ownership in Switzerland since 1983. The proposed changes are significant. Under the proposals, nationals from outside the EU and EFTA would require authorisation before buying a primary residence. If they subsequently leave Switzerland, they would have two years to sell the property or face legal consequences. Foreign buyers would lose the ability to purchase commercial property for rental purposes. Cantonal quotas for holiday home purchases would be reduced. And transactions between foreign owners — where a non-resident sells to another non-resident — would once again require official approval.
These proposals are out for consultation until July 2026 and are not yet law. They form part of a broader political moment: Switzerland goes to referendum on June 14th on an initiative known as "No to Ten Million" — a proposal to formally cap the country's population through immigration controls — and the Lex Koller review has been framed as part of the accompanying policy response.
If enacted, the proposed rules would fall most heavily on nationals from outside the EU and EFTA — which in practice means most internationally mobile buyers: Americans, Australians, South Africans, Gulf nationals, and British citizens who since Brexit are treated as third-country nationals under Swiss law. For all of these buyers, the authorisation requirement would apply. The resale obligation on departure would apply. The reduced holiday home quotas would apply.
Switzerland was not frictionless for foreign buyers even previously — Lex Koller has always imposed some constraints — but the direction of travel is now unambiguously towards greater restriction rather than less, and the political pressure driving these proposals shows no sign of easing.
It is worth being clear about what Switzerland is not doing. It is not restricting EU and EFTA citizens in the same way. It is not dismantling its lump-sum tax arrangements. It remains an exceptional place to live by almost any measure. But for buyers from outside the European system, the barriers are rising — and property is where that shift is being felt first.
Italy does not impose nationality-based restrictions on property ownership. There are no quotas, no authorisation requirements based on where you hold your passport, and no resale obligations tied to your continued residence. The legal framework for overseas buyers is straightforward: anyone can purchase, subject to a reciprocity principle that in practice covers virtually every nationality that commonly looks to buy in Italy.
Beyond openness, Italy actively incentivises purchase as a primary residence. The prima casa regime can reduce the registration tax at purchase from 9% to 2% for qualifying buyers who establish residency within 18 months of completion. On a €500,000 property, that single benefit is worth €35,000 at the point of purchase. Ongoing, qualifying primary residents are exempt from the annual IMU municipal property tax that non-resident owners must pay — a saving that compounds across years of ownership.
| The question | Switzerland | Italy |
|---|---|---|
| Can a non-EU national buy freely? | Proposed — authorisation would be required; resale obligation if you leave | Broadly yes — open to most nationalities subject to standard reciprocity provisions |
| Holiday home purchase | Cantonal quotas proposed to be reduced; increasingly restricted for non-EU/EFTA buyers | No restrictions or quotas; standard 9% registration tax applies |
| Primary residence benefit | No equivalent purchase tax reduction | Can reduce registration tax to 2% (vs 9%) for qualifying buyers, plus IMU exemption |
| Policy direction | Tightening — proposed reforms part of a broader political shift to limit foreign access | Stable and open — no proposed restrictions on foreign ownership |
There is a third dimension to this picture that most internationally mobile individuals have never encountered — and it changes the conversation considerably for anyone drawn to the Switzerland region but put off by its property restrictions.
Italy and Switzerland share a 740-kilometre border running through Valle d'Aosta, Piemonte, Lombardy and Trentino on the Italian side, facing the Swiss cantons of Valais, Ticino and Graubünden. Along this border, a legally distinct category of worker has existed for over fifty years: the lavoratore frontaliero — the frontier worker. Around 65,000 people currently cross this border every working day.
A frontaliero is someone who lives in Italy, within the eligible border municipalities near the Swiss border, and crosses into Switzerland to work — specifically in the cantons of Ticino, Valais or Graubünden. They live in Italy. They earn in Switzerland. Under a bilateral tax treaty between the two countries, they do so within a defined, legally protected framework that prevents double taxation.
The original agreement dates from 1974. A new Italy-Switzerland cross-border worker agreement, signed in December 2020 and in force from January 2024, updated the framework for the first time in fifty years. Under the current rules, Switzerland retains limited taxing rights on employment income through withholding tax, while Italy taxes the same income and grants a credit for the Swiss tax already paid — a coordinated system, not a loophole.
There is one further update worth knowing. A protocol governing remote work was signed in 2024 and ratified into Italian law in January 2026. Frontalieri can work from their Italian home for up to 25% of their annual working hours without losing their frontaliero status — subject to applicable employer arrangements and social security rules. One day working from home per week fits comfortably within this threshold for most employment patterns.
What this creates, in plain terms, is a way of accessing Swiss employment — Swiss salaries, Swiss social security, Swiss professional networks — while living in Italy, owning Italian property, and benefiting from Italy's property purchase framework. The eligible municipalities sit within the Italian border regions of Lombardy and Piemonte: Como, Varese, the shores of Lake Maggiore and Lake Como, and the wider hinterland bordering Ticino and Graubünden. These are not peripheral locations. Many are among the most sought-after addresses in northern Italy — well-connected, scenically exceptional, and materially less expensive than equivalent addresses on the Swiss side of the border.
The contrast with Switzerland's proposed property changes brings this into sharp focus. Anyone who wants to be near Switzerland, access Swiss employment, and own property may soon face a direct choice: buy in Switzerland subject to new authorisation requirements and potential resale obligations, or buy in Italy — broadly openly, and for qualifying buyers under full prima casa rules — and commute across the border as a registered frontaliero. Switzerland, in proposing to tighten its own framework, has inadvertently strengthened the case for the Italian side of the border.
Both Switzerland and Italy reward careful planning. Neither is without complexity. Decisions made in the wrong order in either jurisdiction can be expensive, and the frontalieri arrangement in particular has enough moving parts — eligibility by municipality, the 25% remote work threshold, the interaction between Italian and Swiss tax systems — that professional advice is essential before acting on it.
But the broader point is about trajectory. Switzerland is proposing to add friction for non-EU property buyers, and the political pressure driving that direction shows no sign of easing. Italy is not moving in the same direction. The frontalieri framework has just been modernised for the first time in half a century. And the prima casa benefit continues to reward those who sequence their decisions correctly.
For the right individual in the right location, these things together — open property access, the prima casa purchase benefit, and the frontalieri employment framework — add up to something that the Swiss side of the border, increasingly, cannot match.