The new favorable tax regime for registered sports professionals, applicable to work income from Italian sources, creates various issues. Among those, with reference to the cases in which the operators observed for the substitute tax move back to Italy after having been “lent” for at least two years in a foreign team or others relating to hypotheses of contractual restrictions anticipate with the sports clubs. The most important issue concerns, then, the income portrayed by athletes for the economic exploitation of their intangible rights, a fundamental element to identify the territorial connection criterion for tax purposes and to be related to the requirement of prevalent performance of the activity performed in Italy. Additionally, a special alternative regime has been added, applicable to income from foreign sources for the new “high potential” residents and of which even the top players can make use of art. 24-bis t.u.i.r.

Il nuovo regime fiscale per gli impatriati dello sport professionistico

Laura Letizia
2019

Abstract

The new favorable tax regime for registered sports professionals, applicable to work income from Italian sources, creates various issues. Among those, with reference to the cases in which the operators observed for the substitute tax move back to Italy after having been “lent” for at least two years in a foreign team or others relating to hypotheses of contractual restrictions anticipate with the sports clubs. The most important issue concerns, then, the income portrayed by athletes for the economic exploitation of their intangible rights, a fundamental element to identify the territorial connection criterion for tax purposes and to be related to the requirement of prevalent performance of the activity performed in Italy. Additionally, a special alternative regime has been added, applicable to income from foreign sources for the new “high potential” residents and of which even the top players can make use of art. 24-bis t.u.i.r.
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Utilizza questo identificativo per citare o creare un link a questo documento: https://hdl.handle.net/11591/427153
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