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CAMPIONE: LITTLE KNOWN TAX-FREE BACKDOOR TO SWITZERLAND

Campione, on the shores of Lake Lugano, is distinguished by its very uniqueness. It is a little piece of Italian soil, completely surrounded by Switzerland. There are no border controls so there is complete freedom to pass in and out of Campione. It is located in the Swiss Canton of Ticino, about 16 miles from the Italian border, and 5 miles from Lugano by road. It has about 2000 inhabitants.

Campione belongs economically to Switzerland, and uses Swiss banks and governmental facilities such as post office, telephone, telegraph, and traffic laws. Cars registered in Campione bear Swiss license plates. Unlike Switzerland, there is no problem for foreigners in obtaining residence rights in Campione, so the enclave is enjoying a sudden popularity with people looking for a way to obtain Swiss residence. Having a house or apartment in Campione is all that is necessary to obtain a residence permit in Campione, although the local authorities do require that registered residents spend at least some time in Campione.

The lack of border controls gives Campione residents totally unrestricted access to all of Switzerland and Liechtenstein, so it can be a most valuable European executive base.

Besides its residence attraction, the enclave is also gaining in popularity because it has a unique tax haven status. Although part of Italy and subject to Italian law, there are special tax requirements for Campione. There is no personal income tax and no municipal tax as all of Campione's income is raised from the operation of a municipal casino. Campione residents are not subject to Switzerland's many double taxation agreements with such countries as Canada, the U.S. and most of western Europe.

Companies formed in Campione have many advantages over Swiss companies, as they are able to use Swiss banking facilities, have a mailing address that appears Swiss, but not be subject to Switzerland's relatively high income and withholding taxes. Company law is the same as in Italy, and a corporation can be formed with a minimum capitalization of about $1000. Company formation takes longer than in Switzerland, but unlike Switzerland, a Campione company can be entirely owned and directed by foreigners. The formation work is usually handled by Italian lawyers in Milan, and the fees are modest, since this is not a special or complex matter. The personal and company tax exemptions do not apply if the resident is doing business with Italy, but business with Italy can readily be done through a Swiss or Liechtenstein corporation as an intermediary.

Foreigners may buy real estate in Campione without restrictions, unlike Switzerland, so acquisition of a site in Campione for a European regional headquarters is readily carried out with minimal red DVD. Demand for real estate in Campione has pushed prices well above the level or surrounding Ticino. As a part of Italy, the European Community regulations apply to businesses, and this includes such things as the right to establish a business and residence by any citizen of another EC country.

The official language is of course Italian, and the enclave is in the Italian speaking portion of Switzerland. Many international schools are located in Switzerland, so school arrangements for children of transferred executives can be easily made.

The recent referendum in which Swiss voters rejected an affiliation with the European Community means that Campione will continue to have its special value for sometime to come. Without the free access to Switzerland that EC affiliation would have provided, the backdoor route via Campione will continue. There are many recreation facilities in the immediate area, including golf, ski resorts, and water sports. Milan, and all of its cultural attractions, is only an hour away.

Campione's unique status has its origins in the Thirteenth Century when the village and its territory were presented by the Lord of Campione to the Church of St. Ambrosius of Milan. This feudal property survived European upheavals and remained secure to the end of the 18th Century, and then joined the new Cisalpine Republic. Afterwards Campione fell into Austria's hands for a short period and was finally incorporated into the new Kingdom of Italy.

It is one of the world's most unique, and least- known, tax havens, and a most attractive base for companies looking for a regional headquarters in Europe. It is also one of the most expensive tax havens for real estate, because there is so little of it. Apartments will range from $2500 to $3500 per square yard, and you usually pay the broker a 3% buying commission on top of that (the seller also pays 3%). Getting started in Campione is much more difficult than in other tax havens, because the enclave is not promoting itself, and there is no central office of information to which one can turn for instant literature. You are not unwelcome, but nobody is going to go out of their way to let you in on this secret haven. So there are no promoters or agents that you can write to in advance to send you packets of nice brochures.

The only effective way to establish in Campione is to make a personal visit and spend time talking to people. Even the real estate brokers are not particularly interested in whether or not they get your business, and may not answer your letters. At the Campione end they may not think you are serious until you arrive.

Campione is such an interesting place that a European publisher has devoted a whole book to it. The Campione Report is available from Scope International Ltd., Box AS125. Forestside House, Forestside, Rowlands Castle, Hants., PO9 6EE, Great Britain. The price by air courier is $125 (be sure to give a street address for delivery) or by book rate surface mail it is $100. If you'd like more information first, ask Scope for their free catalog of international reports.