How footballers transferring to Italy can benefit from the country’s new income tax regime for sportspersons

Published 28 August 2019 By: Dr Mario Tenore

Italy Football

Italy has recently introduced attractive tax measures aimed at fostering professional sports. In particular, the so called “Decreto Crescita1 (the Decree) has reshaped existing rules for inbound workers, introducing a specific regime for professional sportspersons (which in Italy means participants in football, cycling, golf and basketball2) who are willing to work and transfer their tax residence to Italy from 2020 onwards (the Regime).

The Regime should help foster the inbound transfers of players. Italian clubs negotiating players’ remuneration on a net basis are also taking advantage of a cost saving as a consequence of the reduced tax burden. Because of the Regime, clubs will be able to offer a lower gross salary and are thus incentivized to acquire foreign players rather than players who are tax resident in Italy or those who are not eligible for the application of the regime.

This article takes a closer look at the practical application of the Regime within the context of an overseas footballer signing for an Italian club. Specifically, it looks at:

  • When and how the Regime applies;

  • Why “tax residency” is a crucial element and how it is determined;

  • The three key conditions for applying the Regime; and

  • What happens if the conditions are not met (if, for example, the player’s contract is terminated early).

For readers wanting a general introduction to the new Regime for inbound workers (and the corresponding regime for high net worth individuals willing to relocate to Italy) please read this article first: How Italy’s favourable new tax regimes can benefit the sports industry3.


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Dr Mario Tenore

Dr Mario Tenore

Dr. Mario Tenore practices at Maisto e Associati (Milan office) and is member of the International Tax Entertainment Group (“ITEG”). He obtained a PHD in tax law (cum laude) from the II University of Naples (Italy) and an LL.M. Degree (cum laude) in international tax law from the University of Leiden (The Netherlands). One of his areas of expertise is taxation of entertainers and sportspersons. In football matters, he provides advice to clubs, players and their agents in relation to tax issues on domestic and international transactions. He has gained in particular experience on tax issues arising in respect of international transfers, management of image rights, payments to agents and others.He has extensively published in international tax journals and books and he is lecturer on international tax law matters at several academic masters and programs in Italy and Europe.

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