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Mario Tenore

Associate Partner

Mario is specialized in taxation of individuals, in particular high net worth individuals, family wealth management, succession planning. He has gained a significant competence with regard to tax related matters in the sport and entertainment industry.

In the sport field, he has advised several sports clubs, federations, professional athletes (including footballers and professional drivers in Formula 1 and MotoGP) and football agents.

He has advised on the most important international transfers of players to Italian clubs as well as on the conclusion of relevant sponsorship and image rights agreements, mostly in football and Formula 1. He has a vast knowledge of the Italian special tax regime applicable to professional sportspersons moving to Italy (including football players, coaches) as well as the of the flat tax regime that may provide significant tax benefits to sportspersons that mainly perform abroad (Formula 1 drivers, MotoGP drivers).

He has represented before Italian Tax Courts clients in sport related cases dealing with tax residence of sportspersons, taxation of fringe benefits (for football players) and the application of special tax regime applicable to professional sportspersons moving to Italy.

He has been appointed as witness expert on tax matters in several CAS cases and sport arbitrations. In parallel to sport tax matters, he has gained a significant experience on tax optimization of estate planning, transfers of businesses and lifetime assets, trusts and foundations tax structuring of charities and other non-profit organizations.

Pirola Pennuto Zei e Associati has a strong private clients practice also in respect of legal (non-tax) aspects covering civil matters related to private clients and wealth management.

He is a visiting lecturer at the LL.M. Programme of the University of Amsterdam, where he teaches on Article 17 OECD Model (Entertainers and Sportspersons) and is often invited as a speaker at seminars and conferences on national and international tax issues relating to sport matters.

He is the author of several contributions in Italian and in English and tax related matters for the sport industry.

He is member of the Associazione Italiana Avvocati dello Sport and member of the of the International Fiscal Association.


  • Private Clients
  • Taxation of Sportspersons
  • Taxation of Entertainers
  • Tax Planning
  • Tax Litigation
  • Corporate tax


  • English
  • Italian
  • French



Mario Tenore