With the statement of practice no. 38 of 30 June 2023, the Italian Tax Agency provided clarifications on the application of the special inbound workers regime for sportspersons (50% exemption of taxable income for workers who transfer their residence to Italy).
For the Italian Tax Authorities, the special regime for sports people only concerns income derived from sports contract. Income deriving from the transfer of image rights, or from advertising promotion activities, may therefore only be eligible for the beneficial tax regime if earned within the framework of the sports employment relationship with the same employer.
Fees from image rights received from third parties, on the other hand, do not fall within the perimeter of the inbound workers regime. The Tax Authority has essentially confirmed what has already recently been established by the Tax Court with reference to an important foreign sportsman who played in Italy.
