Wealth Monitor | November 2025
Italy and Switzerland: Navigating Two Legal Frameworks
The comparison between the Italian and Swiss succession systems highlights substantial differences that affect every stage of planning: from the choice of applicable law to the determination of the competent jurisdiction, from heirs’ entitlements to the management of property regimes, up to the validity of succession agreements and tax implications. In Switzerland, the legislation offers greater flexibility, both in testamentary freedom and in the possibility of entering into inheritance contracts. In Italy, a more protective framework prevails, with restrictions imposed by forced heirship rules and the prohibition of succession agreements, albeit with some recent openings at the European level.
Introduction
Severino Pugliesi - CEO LAGOM Family Advisors
The topic of succession planning between Italy and Switzerland is highly relevant and timely, especially for the many Italian citizens residing in Ticino and registered with AIRE. The geographical proximity, family and asset ties between the two countries, and recent regulatory developments—particularly the revision of the Swiss Private International Law Act (LDIP) and jurisprudential openings at the European level—make a technical and operational in-depth analysis both appropriate and useful.
In our experience, the greatest risks to the generational transfer of wealth do not stem so much from market volatility or financial returns, but rather from incomplete or outdated succession planning, which can lead to legal uncertainty, disputes, and loss of value.
This document is available in Italian only
The sections concerning Swiss law were prepared by Fabio Soldati, while those on Italian law were authored by Maddalena Ferrari.