The Italian tax authorities (ITA) have recently issued four rulings – Nos. 199/2025, 98/2025, 81/2025 and 12/2025 – on the domestic and treaty treatment of deferred remuneration in cross-border employment. Ruling Nos. 98/2025 and 12/2025 reaffirm an accrual-based allocation based on where the work was physically performed, irrespective of subsequent changes in residence. By contrast, Ruling No. 199/2025 – revisiting the fact pattern of Ruling No. 81/2025 – marks a decisive shift back to the pre-2023 “residence-at-payment” approach seen in earlier stock option cases. This note outlines each ruling, highlights the tension within the ITA’s reasoning and considers practical implications for employers and internationally mobile workers.
Barcellona et al. (Tue,) studied this question.