football stadium in Milano, Italy

Wealth Planning for Professional Athletes: Special Tax Incentives in Italy

By Beatrice Molteni, Loconte & Partners

As commonly known, in Italy the sports industry, and especially soccer, represents an important source of wealth for the country.

Italian culture is strongly supportive of the phenomenon and it embraces all aspects concerning the sports industry. As a matter of fact, it is hard to find someone in this country that has no interest in sport, and it is even harder to find a child who has not a sport icon in his mind and who does not dream about becoming a soccer player or a basketball player in the future. This means that the sport industry is one of the most dominant players in the Italian economic field and, year after year, it is reaching values (now estimated to be more than EUR 3 billion) as never before.

As a consequence of the potential growth of this industry, in 2019 the Italian legislature introduced special tax incentives for athletes that move to Italy for work.

The so called “Growth Decree” no. 34/2019 (converted into law on 28 June 2019 and entered into force on 30 June 2019) introduced some amendments to the special tax regime for attracting human capital to Italy, pursuant to article 16 of Legislative Decree No. 147/2015, including new tax incentives for professional athletes and other inbound workers who transfer their tax residences to Italy starting at 2020.

The aim of the legislation, with the introduction of the provisions of the Growth Decree no. 34/2019, is to attract professional athletes, providing them strong fiscal advantages as long as certain requirements are met. More specifically, such taxation regime applies to all professional athletes who decide to move to Italy to play or work for Italian sports clubs starting in 2020.

First of all, to be admitted to this “special regime”, the professional athletes have to meet the following conditions:

  1. Have lived as Italian tax nonresidents for the previous two years before transferring their tax residences to Italy;
  2. Qualify as Italian tax residents and plan to remain in Italy for the next two years; and
  3. Perform the main work activity in Italy.

Moreover, this tax regime applies to all employed (as qualified in article no. 49 Italian T.u.i.r.) and self-employed professional athletes (as qualified in article no. 53 Italian T.u.i.r.).

The professional athletes that transfer their tax residence to Italy could be subject to Italian personal income tax on 50% of their employment income from Italian sports clubs, while the remaining 50% of income from Italian sports club would be exempt from taxation.

This special tax regime would be applicable for five years, but there is also the possibility of extending the tax advantages for other five years if, during the first five-year period, the taxpayer becomes the owner of at least one residential real estate unit in Italy after being transferred to Italy (or if the taxpayer becomes the owner of at least one residential unit in Italy within the twelve months prior to his/ her transfer) or if the taxpayer has at least one minor or dependent child, even in pre-adoptive foster care.

In addition, a special contribution of 0.5% will be due on the taxable base of the income earned in Italy to support the professional athlete’s confederation for young athletes in the future.

Concerning the “fringe benefits” related to the working relationship received by the professional athlete, they are included in the special tax regime. The same consideration applies to the sponsorships, merchandising, and endorsement agreements of the professional athletes under the direct control of the Italian sports club.

In conclusion, it is reasonably clear why it is very convenient for athletes to take advantage of the fiscal opportunities related to the decision to move to work and play in Italy in the near future and, at the same time, it represents a unique chance for Italy to attract people with massive assets.

Beatrice Molteni

Beatrice Molteni

GGI member firm
Loconte & Partners, Studio legale e tributario
Advisory, Auditing & Accounting, Corporate Finance, Fiduciary & Estate Planning, Law Firm Services, Tax
Bari, Italy
T: +39 080 572 2880
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Loconte & Partners is a law firm specialising in tax and legal consultancy that assists its Italian and international clients, helping them to preserve and grow their wealth.

Beatrice Molteni is a Member of the Global Wealth Management Team of Loconte & Partners. After graduating in Law, she completed a postgraduate degree focused on wealth management and asset protection. She specialises in the wealth and estate planning area and in advisory to the private clients for asset protection, including both domestic and international clients.

Published: Trust & Estate Planning Newsletter, No. 06, Autumn 2020 l Photo: Wirestock -

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