Counsel Milan
"The regime is centred around two main points: tax incentives for legal entities in the form of IRES and IRAP exemptions and tax benefits for individuals through full or partial IRPEF exemptions."
Following the conversion into law of Law Decree no. 38 of 27 March 2026 (“Decree”), the Italian legislator has introduced a package of special tax measures aimed at enhancing Italy’s attractiveness for international stakeholders involved in the 38th edition of the America’s Cup which is being held in Naples in 2027.
The regime is centred around two main points: tax incentives for legal entities in the form of IRES and IRAP exemptions and tax benefits for individuals through full or partial IRPEF exemptions.
1. IRES/IRAP EXEMPTION FOR ORGANISING ENTITIES AND TEAMS
Article 8, paragraph 4-novies, of the Decree introduces a significant tax benefit for entities involved in the organisation of the America’s Cup.
Those eligible include:
- legal entities with a registered office in Italy; and
- legal entities established in 2026 by the organising body or participating teams.
Such entities benefit from an exemption from IRES and IRAP for the fiscal year from 1 January 2026 to 31 December 2027. The relief is limited to activities carried out in accordance with the entities’ institutional purposes and directly and exclusively related to participation in the event.
The same regime applies to Italian permanent establishments of foreign entities set up in Italy in 2026 in connection with the event by the organising body or the participating teams. In such cases, the IRES and IRAP exemption applies under the same conditions and is restricted to activities directly connected with the event.
2. TAX REGIME FOR WORKERS
Article 8, paragraph 4-decies, governs the tax treatment of individuals involved in the event, establishing a differentiated regime depending on their tax residence.
2.1 Non-resident workers
Non-resident individuals performing services for the organiser or participating teams in connection with the America’s Cup and directly connected with their participation in the event, without transferring their tax residence to Italy, can benefit from a full IRPEF exemption on employment income, equivalent income, and self-employment income earned in 2026 and 2027, provided such income is directly connected with the event.
Such compensation is not subject to taxation in Italy. Additionally, such income is not subject to withholding taxes, whether on account or final, nor to substitute income taxes.
Key contacts
"This benefit is conditional upon a direct link between the income and the event."
2.2 Workers transferring tax residence to Italy
Individuals who transfer their tax residence to Italy to carry out activities connected with the event are subject to tax on up to 35% of the relevant income earned in the 2026–2027 period, with the remaining 65% exempt from IRPEF taxation.
This benefit is likewise conditional upon a direct link between the income and the event.
2.3 Non-cumulability rule
The benefits provided in the Decree under paragraph 4-decies cannot be combined with other existing preferential tax regimes.
Notably, they are not available in conjunction with:
- the inbound workers regime (article 5 of Legislative Decree no. 209/2023);
- the regime for professors and researchers relocating to Italy (article 44 of Law Decree no. 78/2010); and
- the new residents regime (article 24-bis of the Italian Income Tax Code – TUIR).
Key contacts
Counsel Milan
Associate Milan
Associate Milan
