The ‘impatriate workers’ regime and its application in football

In the context of tax relief in the professional sports sector, the system of so-called “impatriate workers”, provided for by art. 16 of Legislative Decree 147/2015, is destined to take on particular importance.

The extension of this concessionary regime to professional sportsmen and sportswomen results from the disappearance of the requirement of high qualification or specialisation as a result of the changes introduced by Article 5 of Legislative Decree 34/2019 (the so-called “growth” decree).

That said, DL 34/2019 raised the share of exempt income to 70% and, in some cases, to 90% (before the changes in question, the share of non-taxable income was 50%).

The requirements for the applicability of the facilitation scheme are as follows:
– the work activity must be carried out mainly on Italian territory.
– the applicability of the regime is subject to the condition that the player was not resident in Italy in the two tax periods preceding the transfer.
– the player must maintain his residence in Italy for at least two years.

The regime is applicable to players who acquire residence in Italy from 2020.


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