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Italian Revenue Agency scores again on the tax treatment of Cristiano Ronaldo's image rights income

Man Calculating Tax
Tuesday, 12 September 2023 By Dr Mario Tenore

The Second Instance Tax Court of Piedmont issued its judgment no. 219 of 15 May 2023 (“Decision”) regarding the tax treatment of income deriving from the exploitation of image rights by Cristiano Ronaldo (CR) in the context of the Italian flat tax regime (“Regime”) pursuant to 24-bis of the Decree n. 917 of 22 December 1986 (“CTA”) discussed below in detail.

In this case, the question was whether income from the exploitation of image rights paid by foreign entities to Cristiano Ronaldo could qualify as foreign source income and could therefore benefit from the Regime (with a flat tax of €100,000) rather than taxed as part of personal income tax (taxed at roughly 45%).

This article discusses the case and its impact on the applicability of the Regime.

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Dr Mario Tenore

Dr Mario Tenore

Dr. Mario Tenore is an associate partner at Pirola Pennuto Zei & Associati and is member of the International Tax Entertainment Group (“ITEG”).

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