America’s Cup: 65 per cent tax relief for residents too

America’s Cup, a 65 per cent tax relief also applies to those already resident in Italia. Employees and self-employed workers who will be working during the 2027 America’s Cup in Naples will be able to benefit from a range of tax relief measures depending on the location of the worker’s tax residence. Under Article 8, paragraph 4-decies, of Decree-Law 38 of 27 March 2026 (Law No. 88 of 22 May 2026), as subsequently amended by Decree-Law 108 of 26 June 2026 (Law No. 142 of 4 August 2026), two separate tax relief measures were introduced for workers involved in the sporting event in question.

Firstly, for individuals who are not tax residents in Italia and who provide services to the organising body or to the teams participating in the sporting event, there is total tax exemption on income from employment, similar sources and self-employment received in 2026 and 2027. Employers/clients will therefore not be required to withhold any tax on the remuneration paid to such workers, and the latter will not be required to pay tax on income of Italian source deriving from their participation in the America’s Cup.

Income from self-employment, employment and similar sources paid to individuals who are tax residents in Italia in connection with this event is, however, taxable at a rate of 35 per cent of the total amount. In the original version of the legislation, the relief applied only to new residents (i.e. from 2026 or 2027), whereas under Article 3 of Decree-Law 108 of 26 June 2026, the income tax relief was extended not only to those moving to Italia to take part in the sporting event, but also to individuals who are already tax residents in Italia. This relief cannot be combined with the new or old schemes for repatriates, with the scheme for lecturers and researchers, with the scheme for new residents, or with the 7 per cent flat-rate tax scheme for recipients of pensions from abroad.

The preferential scheme provided for under the America’s Cup guarantees a higher tax relief for the two-year period 2026–2027 than the new ‘impatriate’ scheme, which, by contrast, provides for a 50 per cent reduction in taxable income but has a more limited duration (two years rather than five). In order to assess which tax relief is more advantageous to apply from a multi-year perspective, clarification of the Revenue Agency’s practice would be desirable to understand whether, once the two-year preferential period under the America’s Cup scheme has ended, the new repatriation scheme can be applied for the following three years.