Taxation of Image Rights: Remarks in Light of the Cristiano Ronaldo Case and Recent Amendments to the Italian Income Tax Code

In this note, the author analyses the complex Italian tax framework governing income from the exploitation of image rights by athletes and celebrities. After outlining the main interpretative approaches that have emerged over time, it focuses on the landmark case involving Portuguese footballer Cristiano Ronaldo during his tenure at Juventus football club. The discussion concludes with an assessment of the recent amendments to the Italian Consolidated Income Tax Act and their potential impact on the taxation of image rights in the sports and entertainment industries.