America’s Cup: two-year exemption from IRES and IRAP for all competing teams
To qualify for the benefit, you must keep separate accounts
Legal entities with their registered office in Italia, established by the organising body or by the participating teams in the America’s Cup Napoli 2027, will be eligible for a range of tax and employment law concessions.
IRES and IRAP relief
Firstly, these entities will be eligible for the IRES and IRAP exemption in respect of activities carried out in accordance with their institutional purposes during the period from 1 January 2026 to 31 December 2027. The tax relief in question, introduced by Article 8 of Decree-Law No 38 of 27 March 2026, was subsequently amended by Decree-Law No 108 of 26 June 2026.
The condition for qualifying for the tax relief is, in fact, the establishment of a specific separate set of accounts in which all income and expenditure items directly and exclusively related to participation in the sporting event are recorded. The tax relief in question also applies, under the same conditions, to permanent establishments set up in Italia for the duration of the event by the organising body or by the participating teams.
VAT refunds
Under Article 3 of Decree-Law No 108 of 26 June 2026, the scope was extended the right to a refund of value added tax, as provided for in Article 38-bis2 of Presidential Decree 633/1972, to entities established in third countries without a permanent establishment in Italia, thereby removing the requirement of reciprocity (i.e. the condition that the country of establishment grants similar treatment to Italian operators).
For the 2027 America’s Cup, however, the legislator has introduced an explicit exemption, justified on the grounds of the public interest associated with the staging of the event. The waiver of the reciprocity requirement applies exclusively to VAT paid on purchases and imports of goods and services made within Italy and directly necessary for the conduct of activities related to the event.
