Italy: 2025 Budget Law Enhances Tax Relief for Olympic Medalists

By Alberto Brazzalotto and Federico Maria Cagnola, Maisto e Associati, Lawyers, Milan, Rome and London

Italy will host the Winter Olympic and Paralympic Games in Milan-Cortina in 2026 (the “Games”). In this context, the Italian government has introduced specific measures to provide tax benefits and reliefs for eligible stakeholders involved in this event.

Recently, with the enactment of Law No. 207 of December 30, 2024 (the “2025 Budget Law”), the Italian government introduced a tax incentive for athletes representing Italy at the Games who achieve medal-winning performances.

Specifically, Article 1, paragraph 262 of the 2025 Budget Law (the “2025 Provision”) stipulates that income awarded by the Italian National Olympic Committee (CONI) and the Italian Paralympic Committee (CIP) for such achievements will be exempt from Italian withholding tax[1]. More broadly, these amounts will be excluded from the recipient’s taxable income.

To qualify for this exemption, all of the following conditions must be met:

1. The income must be paid by CONI or CIP (meaning the athlete must represent Italy in the Games) [2];
2. The recipient must be an athlete participating in the Games;
3. The payment must be related to a medal-winning performance.

The 2025 Provision further integrates the existing regulatory framework concerning the tax treatment of remuneration for athletes participating in the forthcoming Games. In particular, Article 5, paragraph 3, of Legislative Decree No. 16 of 11 March 2020 (the “2020 Provision”) exempts from taxation the remuneration accrued by non-Italian tax resident athletes for performances rendered in Italy in relation to the Games.

However, the 2025 Provision and the 2020 Provision appear to have distinct subjective and objective scopes of application. Namely:

• With reference to the subjective scope of application, the 2025 Provision applies only to Italian citizens who represent Italy during the Games, regardless of their tax residency. By contrast, the 2020 Provision applies to the athlete’s tax residency, applying solely to athletes who are not tax residents of Italy, irrespective of their nationality and the nation which they represent;
• As to the objective scope of application, whilst the 2020 Provision appears to have a broader scope, encompassing all forms of compensations received by athletes in relation to their performances rendered in Italy during the Games, the 2025 Provision seems to adopt a more limited scope, applying exclusively to prizes awarded by CONI or CIP in connection with medals achievements.

In conclusion, the analysis underscores a lack of coordination between the two provisions, which could lead to inconsistencies across different scenarios. For example, although an Italian citizen representing Italy in the Games who is a tax resident abroad may be eligible to benefit from both rules, the same cannot be said for a foreign athlete who is a tax resident in Italy. In the latter case, the athlete appears to be excluded from the scope of both the 2020 and the 2025 Provisions, thereby highlighting a potential issue that warrants further attention.

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[1] The 2025 Provision explicitly references the withholding tax regime established by Article 30 of Presidential Decree No. 600 of 29 September 1973. Under this provision, income derived from prizes awarded for sports competitions is subject to a 20% final withholding tax.

[2] It is important to note that the International Olympic Committee typically does not award monetary prizes directly to athletes for medals won. Instead, each National Olympic Committee determines and disburses the respective prizes to its athletes.