Italy Clarifies Tax Rules for Amateur Sports Organizations

Context

The 2021 sports labor reform (D.lgs. n. 36/2021) introduced significant changes to the Italian sports sector, particularly for amateur sports organizations. However, the reform left many practical questions unanswered regarding tax treatment of various income streams and contractual relationships. Circular 7/E, published on 7 August 2026, provides much-needed clarification from Italy's tax authority.

This guidance arrives amid growing complexity in the amateur sports sector, where organizations must navigate both sports-specific regulations and general tax law. The circular addresses key areas of concern for practitioners, including income taxation thresholds, treatment of volunteer reimbursements, IRAP (Regional Production Tax) exclusions, VAT exemptions for sports services, and requirements for maintaining non-profit status.

Income Taxation and Volunteer Reimbursements

One of the circular's most significant clarifications concerns income taxation. It confirms a €15,000 annual non-taxable threshold applicable across all sports work contract types within amateur sports. This includes:

• Dependent employment contracts
• Coordinated continuous collaboration (co.co.co.) agreements
• Autonomous work relationships

Volunteer forfeit reimbursements of up to €400 per month count toward this annual ceiling. Any amounts exceeding the threshold become fully taxable and subject to withholding obligations. This clarification helps organizations better manage their budgeting for volunteer compensation while ensuring compliance with income tax regulations.

IRAP Exclusions and VAT Treatment

For IRAP purposes, the circular clarifies that all co.co.co. relationships in amateur sports benefit from an exclusion from the taxable base up to €85,000 annually. This applies not only to athletic roles but also administrative and management positions.

Regarding VAT, organizations seeking to invoke the exemption for amateur sports services under art. 36-bis of D.L. 75/2023 must file prior notification with the competent tax office before claiming invoicing and registration exemptions. Notably, the transfer of athlete service contracts from amateur to professional sports organizations is treated as a financial/commercial operation and remains subject to the standard VAT rate, with no exemption available.

Non-Profit Requirements and Fundraising

The circular also addresses statutory non-profit requirements for limited liability sports societies (SSD). It confirms that those operating under 'attenuated' non-profit status must maintain an absolute prohibition on indirect profit distribution in their statutes to qualify for commercialization exemptions.

Regarding fundraising, the circular confirms that the L. 398/1991 regime applies to all amateur sports organizations, including those structured in corporate form. This regime allows for tax-free treatment of commercial revenue and public fundraising up to two events per year, with a maximum of €51,645.69.

Implications for Practitioners

The circular provides much-needed clarity for accountants, tax advisors, and sports administrators working with amateur sports organizations. Key implications include:

1. Budgeting and Contract Management: Organizations can now better plan their budgets around the €15,000 non-taxable income threshold and €85,000 IRAP exclusion.
2. Volunteer Compensation: Clear guidelines on volunteer reimbursements help prevent unintended tax liabilities.
3. VAT Compliance: The requirement for prior notification before claiming VAT exemptions means organizations must plan ahead when structuring their sports service offerings.
4. Non-Profit Compliance: The clarification on 'attenuated' non-profit status helps organizations maintain their tax-exempt status while engaging in commercial activities.

Outlook and What to Watch

As of 21 September 2026, Circular 7/E remains the governing guidance with no superseding circulars or legislative amendments published. Practitioners should:

1. Monitor for any updates or additional guidance from Agenzia delle Entrate.
2. Review existing contracts and financial arrangements to ensure compliance with the circular's provisions.
3. Stay informed about any legislative changes that might affect amateur sports organizations.