Italian Revenue Agency scores again on the tax treatment of Cristiano Ronaldo's image rights income
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.
To continue reading or watching login or register here
Already a member? Sign in
Get access to all of the expert analysis and commentary at LawInSport including articles, webinars, conference videos and podcast transcripts. Find out more here.
- Tags: Dispute Resolution | Football | Image Rights | Italy | Regulation & Governance | Sport | Tax Law
Related Articles
- A Guide To UK Tax Rules For Overseas Sports Stars
- The Lifecycle Of An International Athlete - Key UK Income Tax Considerations For Non-Residents
- How Italy Has Reshaped Tax Incentives To Attract Professional Athletes
- Financial Woes: What Worcester Warriors & London Wasps' Struggles Mean For English Rugby
- Working as a football agent in Italy: Complying with the FIFA's Football Agent Regulations & Italian law
- Football agents (PROFAA) v FIFA – CAS’s biggest EU competition law decision yet?
Written by
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”).
