Tax changes for elite athletes presently in Italy: What you need to know (Part 1)

This article provides a helpful guide to the recent changes to the Italian tax regime that directly impacts the taxation of elite athletes’ income in Italy, and will be of interest to professional sportspersons and their representatives who play/compete in Italy and covers:

• The new regime
• A recap of the sportspersons regime and the transitional rules.
  • An overview of the sportspersons regime
  • Analysis of the transitional rules
• Conclusion

Prior to 2024, the Italian tax systems entailed two regimes potentially attractive for sportspersons:

• The “flat tax regime” - a tax regime through which a flat tax is imposed on certain income as opposed to being applied to different tax brackets.
• The “impatriate tax regime” (prior to 2024 referred to as “Old Regime”) - a regime that deals with taxation on domestic income, and has specific provisions dealing with taxation on incomes of athletes. The regime has been recently amended with effect as from 1 January 2024 (“New Regime”).

The recent amendments  have led to the repeal of the rules governing the Old Regime (see Article 5(9) of Legislative Decree No. 209 of 27 December 2023 ("Decree"))^[1], prior to 2024, including the rules for professional sportspersons (“Sportspersons Regime”).