ANIF Conference

Sports Reform: Leo and Abodi debate Circular 7/E – the new rules for ASDs and SSDs

The proceedings were opened by ANIF President Giampaolo Duregon. Seated at the institutional table were the Deputy Minister for the Economy, Maurizio Leo, and the Minister for Sport, Andrea Abodi, who joined the meeting remotely. The technical discussion was also attended by Mauro Rizzolo (Confindustria Federvarie), Sergio Cristallo, Central Director of Legislation and Litigation at the Italian Revenue Agency, and lawyer Alberto Succi, who led the in-depth discussion on practical application.

2' min read

Translated by AI
Versione italiana

2' min read

Translated by AI
Versione italiana

An incentive to clarify, rather than to regulate: this is the thrust of Circular No. 7/E, published by the Italian Revenue Agency on 7 August, which was discussed on Thursday in Rome at the conference organised by ANIF in the Multipurpose Hall of the Presidency of the Council of Ministers. The document addresses four key issues relating to the implementation of the Sports Reform (Legislative Decree 36/2021) which, in recent months, had caused operational uncertainty amongst amateur sports organisations.

The proceedings were opened by ANIF President Giampaolo Duregon. Seated at the institutional table were the Deputy Minister for the Economy, Maurizio Leo, and the Minister for Sport, Andrea Abodi, who joined remotely. The technical discussion was also attended by Mauro Rizzolo (Confindustria Federvarie), Sergio Cristallo, Central Director of Legislation and Litigation at the Italian Revenue Agency, and lawyer Alberto Succi, who led the in-depth discussion on practical application.

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Leo: ‘Let’s make life easier for taxpayers’

Leo framed the circular as part of a broader drive towards simplification: ‘Our aim is to provide certainty and make life easier for taxpayers’. The Deputy Minister spoke of “clearer rules, less uncertainty and a simpler relationship with the tax authorities”, which, according to him, applies “not only to this sector, but to all other sectors as well”.

Abodi on the importance of amateur sport

Abodi, on the other hand, emphasised the target audience: clarity, he said, must reach ‘above all the ASDs (Amateur Sports Associations, ed.) and the SSDs (Amateur Sports Clubs, ed.), which fulfil an extraordinary social role but often lack the appropriate tools to navigate these issues’.

The four questions in the circular

On this matter, the circular addresses four queries. The first concerns the relief provided for in Article 148(3) of the Tuir and Article 4(4) of the VAT Decree: the Agency confirms that these also apply to SSDs established under Legislative Decree 36/2021, provided that their articles of association include the non-profit clauses set out in Article 148 of the TUIR, in addition to those already specified in Articles 7 and 8 of the reform decree.

The second clarification concerns the annual tax-free allowance of 15,000 euros on remuneration for amateur sporting activities, as provided for in Article 36(6) of Legislative Decree 36/2021: the Agency confirms that this also applies to employment relationships, as the provision focuses on the objective nature of the activity rather than the form of the contract. Only the portion exceeding €15,000 forms part of the taxable income in accordance with the standard rules governing employment.

Thirdly, the IRAP exemption of up to 85,000 euros on remuneration for coordinated and ongoing collaboration: the circular extends this exemption to ‘co.co.co.’ workers with administrative and managerial roles, not just to those in the sports sector in the strict sense.

Finally, regarding the VAT exemption provided for in Article 36-bis of Decree-Law 75/2023 for sporting services provided by non-profit organisations, the Agency confirms that ASDs and SSDs may opt for exemption from invoicing and record-keeping obligations, subject to prior notification to the office – an exemption which applies only to exempt transactions, whilst the ordinary obligations for taxable transactions remain in force.

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