Sailing

Tax incentives for the America’s Cup: the range of beneficiaries is expanding – here’s who is eligible

The preferential tax scheme had been introduced by the March tax decree and has now been extended following the approval of the latest Sports Decree by the Council of Ministers

by Lorenzo Pace

 Ricardo Pinto / America’s Cup

3' min read

Translated by AI
Versione italiana

3' min read

Translated by AI
Versione italiana

The special tax regime established around the America’s Cup is being extended. The latest Sports Decree, approved by the Council of Ministers, has broadened the scope of those eligible for the tax relief measures already introduced by the March tax decree, which was enacted into law in May. More businesses, more workers, and a new VAT measure for foreign entities purchasing goods and services related to the event. Let’s look at them in detail.

The starting point: the March tax decree

The initial measures had been introduced via an amendment to the Finance Bill, approved by the Senate Finance Committee and tabled by Fausto Orsomarso (FdI). The principle was clear: for an event of this magnitude — the first America’s Cup to be held in Italia, in Naples in 2027 — a bespoke tax framework was required.

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For businesses, the legislation provided for an exemption from IRES and IRAP for legal entities with their registered office in Italia, established in 2026 by the organising body or by the participating teams. The benefit covered activities carried out between 1 January 2026 and 31 December 2027, provided that they were directly and exclusively related to the event. The same exemption applied to permanent establishments set up in Italia in 2026 for the purposes of the event.

As regards workers, there will be no tax on income from employment, equivalent income and self-employment received in 2026 and 2027 by non-residents in Italia involved in the organisation. No personal income tax (IRPEF), no withholding tax, no substitute tax. For those who transfer their residence to Italia, tax is payable only on 35 per cent of their income.

What’s new in the Sport Decree

The Sports Decree has amended this scope and significantly expanded it in three areas. The first concerns businesses. Under the original legislation, the exemption from IRES and IRAP applied only to companies incorporated in 2026. The decree has removed that time restriction. All legal entities with their registered office in Italia, established by the organising body or by the participating teams — regardless of the year of incorporation — will be eligible for the benefit in respect of activities carried out between January 2026 and December 2027, provided they are directly and exclusively linked to the Cup. The same applies to permanent establishments: here too, the restriction regarding 2026 as the year of establishment has been removed.

The second area concerns workers. The IRPEF exemption scheme, previously reserved solely for non-residents, has now been extended to include individuals who are tax residents in Italia. This covers a much wider group, including professionals, technicians and consultants who are already based in the country but are employed by the event organiser.

The third element is a new development: the VAT refund. Entities established in non-EU countries that purchase goods and services directly related to the event may claim a VAT refund, even in the absence of reciprocity with their country of origin and without the need for a permanent establishment in Italia. This constitutes an explicit derogation from the conditions normally required.

Labour regulations

Alongside tax incentives, the decree has also introduced special provisions governing employment relationships. Fixed-term contracts entered into by the organising body and the participating teams may derogate from the ordinary rules on maximum duration, the number of renewals and the quantitative limits set out in Legislative Decree 81 of 2015. The ceiling remains set at 24 months with the same employee and six renewals. There is also provision for an exemption from social security contributions for employers, with the details to be set out in a subsequent interministerial decree between the Ministry of Labour and the Ministry of Economy and Finance within 60 days of the decree’s conversion into law. The exact amounts have not yet been set.

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