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Campione d'Italia

 
Campione – Tiny Tax Haven in Swiss Alps 

Campione is a tiny Italian enclave surrounded by Switzerland. Located on just 1.6 km of sloping land, residents enjoy an almost unrestricted, panoramic view of Lake Lugano and the surrounding Swiss Alps. In size, Campione ranks as one of smallest tax havens in the world, about ¼ the size of tiny Gibraltar in the Mediterranean Sea, and equal in size with Monaco. 

Campione owes its tax haven status to a more or less laissez-faire attitude by the two neighboring countries (Switzerland and Italy) that rightfully, it would seem, have the jurisdiction to impose taxes on this tiny ink-spot on the map. Although properly the property of Italy, the Italians have never enjo9ined to levy taxes in Campione, partly because Italian tax agents would have to leave Italy and pass through Switzerland to impose Italian law in Campione, and partly because of a mutual understanding with the Swiss that has traditionally kept Campione safe from tax collectors. Switzerland, on the other hand, doesn’t impose its tax laws in Campione, because Switzerland has no jurisdiction to tax. The Italians are the legitimate landlords. Being small and self-governing, Campione has no income taxes and no local taxes. 

The sole source of revenue for the economy is Campione’s famous gambling Casino, which is owned by the Italian government. Because enough revenue is generated by the Casino operations alone to keep the enclave economically self-sufficient and satisfy the Italian government’s own revenue objectives, no effort to levy taxes on residents (foreigners or locals) is likely to occur. Campione would probably disappear as a tourist and business attraction if taxes were levied. As far as the Italians are concerned, why ruin a good thing? Yes? 

Language, Population & Accessibility 

Campione’s official language is Italian and its people are predominantly Italian. In Italy “Campione d’Italia” means “sample of Italy”. English speaking schools can be found in nearby Switzerland, and educational facilities are said to be excellent. A European school in nearby Varese, Italy is also available. 

Geographically, Campione lies within the Swiss canton of Ticino making Campione economically more allied with Switzerland. The Swiss franc is the currency in use, and Swiss telephone and telegraph services handle all the communications for Campione’s 2,500 residents. The Swiss postal system delivers the mail, and if you write anyone in Campione, you always use the Swiss postal code CH-6911. 

Campione resident permits are easy to get, something that cannot be said for Swiss permanent resident permits. Consequently, foreigners often reside in Campione, and make the short trip to Lugano to do their banking and take care of other business. Lugano is only minutes away, across the lake, and some 40+ banks there will welcome your business. Ironically, Campione has no banks or banking system of its own and for this relies on the Swiss. 

Aside from no revenue agents to contend with, there are no border patrols to restrict your crossing Campione’s borders. 

Campione is about an hour by car or express train from Milan, two hours from Zurich, and six hours from Geneva. While there are no direct flights from the USA to Campione, frequent direct flights to the major Swiss cities make Campione only slightly less accessible than the major Caribbean tax havens. 

Company Formation 

Most lawyers and accountants live in Lugano, the center for local banking. It can be said there are two corporate forms a Campione company can take. In addition, the Swiss Aktiengesellsschaft (joint stock company) and the Liechtenstein Anstalt (establishment – a sort of “foundation”) are commonly used when doing business in or from Campione. 

S.R.L. (Societa Responsibility Limitada) is a private limited liability company. The formation time is about two month. During the waiting period it is permitted to operate “under foundation”. Advantages are:

  1. minimum paid-up capital of about $1,000.
  2. Names of shareholders (anonymity) of the company can be kept secret.
  3. Foreigners can start-up and own all the shares of a company, without the need for nominees or resident shareholders. 

S.R.L.’s must keep proper books, and audited accounts must be presented to the Italian authorities each year. If the company does not carry on business with Italy, there is no tax liability to speak of. If it is essential that you carry on business with an Italian firm, it is best to form a Swiss or Liechtenstein intermediary company. 

S.A.S. (Societa Accomandeta Semplice): is a private unlimited liability company. Formation time is about one month. Note, however, this corporation is subject to Italian taxation and anonymity (keeping the real identity of the shareholders a secret is not allowed. The main advantages include:

  1. minimum paid-up capital of about $1,300.
  2. Bookkeeping is “closed” to Italian review.
  3. Business with Italy creates no special tax problems.

 Swiss Aktiengesellschaft (joint stock company) or “A.G.” will obtain the Swiss “domiciliary” status under Swiss law if it does not conduct business in Switzerland (including the canton of Ticino) and is managed from Campione. Swiss Federal taxes at the regular Swiss rates of up to 9.8% apply, with a further reduction if the “A.G.” is merely a “holding company”. Dividends from “substantial holdings” (20% or more) in foreign company” in Switzerland free from the Swiss Federal Tax. 

Liechtenstein Anstalt (establishment) is a special type of company that is commonly used by Campione businesspersons. Formation is quick, anonymity of ownership is allowed, but some taxes in Liechtenstein are incurred, although they are low. 

No Tax Treaties & No Unauthorized Disclosure 

Campione has signed no income tax treaties with any nation, including the USA and Switzerland. Unauthorized disclosure of ones financial affairs would be a violation of local law. 

Interestingly enough, the Swiss-U.S. Income Tax Treaty that allows the exchange of information between the IRS and Swiss tax authorities in specific but limited instances, does not make Switzerland a less attractive tax haven to be domiciled in. The Swiss and U.S. views on tax evasion have always been quite different, and the Swiss refuse to look upon tax evasion as a crime, unless records were falsified. Furthermore, Swiss bank secrecy laws have rarely been successfully penetrated by the IRS or other U.S. investigating bodies when no Swiss laws were broken. 

Case in Point 

Take for example the Iran-Contra arms-for-hostages scandal. It wasn’t a breach of Swiss bank secrecy law that led to the problems Oliver North and General Richard Secord encountered. Why did these entrepreneurs choose to use Switzerland as a base to export arms to the Iranians in the first place? The answer to this question is simple. TAXES. 

Under the Swiss-U.S. income treaty (& before the Tax Reform Act of 1986), a Swiss employee (in this case General Secord or Hakim – both U.S. citizens) of a Swiss company could arrange for the sale of U.S. products (arms) from within the USA, and based on these facts alone, no U.S. income tax would be incurred because the income was considered “foreign source income” so long as the title of ownership was passed outside the USA. The Swiss company’s “foreign source income”. It would even have been permissible if Secord & Hakim opened a Swiss branch office within the USA to help set up the sales. Such income would still be considered from “foreign sources”

Post Tax Reform Act ’86 law made a few material changes to the “sourcing rules”. While the “title passage rule” is still an important factor, it is also important that a foreign office plays a material role in the actual sale or transaction if the income is to be categorized as having a “foreign source”. “new” Section 865(e)(2)(A) states when a U.S. office is involved in the transaction, income is treated as having a “U.S. source” regardless where title passes. This change in the “sourcing rules” could make Swiss exporters that operate through a U.S. branch office liable to federal income tax because the U.S. is allowed to tax “U.S. source income” of a Swiss branch (the treaty uses the term “permanent establishment”), but cannot tax “foreign source incomes”. Luckily, Section §865(e)(2)(B) provides an “exception” from the sourcing rule for inventory, so the Section §865(e)(2)(A) office sourcing rule is overridden.

(Courtesy of New Providence Press: Tax Havens of the World).

Find the contact names, addresses, numbers and information for local government offices, banks, accountants, company formation services, investment and management companies, advisors, experts, maildrops, real estate agents and other useful local contacts in the THE OFFSHORE MANUAL & DIRECTORY.

 
 

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