Working for the America’s Cup in Naples during the period from January 1, 2026 to 2027 is worthwhile: for companies involved in organizing the event and also for individuals (technicians, athletes, and foreign professionals).
Working for America’s Cup in Naples
It is well explained to us in this article by Dr. Luca Valdameri (one of the historical partners of Studio Pirola Pennuto Zei & Associati, which is one of Italy’s top ten legal and tax firms) and the firm’s associate Martina Calissi: an authoritative contribution that precisely maps the advantages for companies and individuals, highlighting the delicate boundary of (non)cumulability with regimes for impatriates or new residents, and also emphasizes the issue of social contributions. Tax advantages aimed at attracting skills, investment and technology to Italy.
America’s Cup Naples 2027: why the IRS opens its sails to international teams
TheAmerica’s Cup is not only the most prestigious sailing competition in the world. It is also the oldest international sports trophy still contested today. Its origins date back to 1851, when the schooner America won a race around the Isle of Wight organized by the Royal Yacht Squadron, winning what was then known as the “100 Guineas Cup.” From that victory was born a challenge destined to become a legend in world sports.
Even today, the competition is held according to the principles set by the Deed of Gift, the act that governs its basic rules. One of the most fascinating features of the Cup is that the winner acquires the right to organize the next edition, choosing its venue and format together with the Challenger of Record.
In recent years, theAmerica’s Cup has stopped in some of the world’s sailing capitals: Auckland in 2021 for the 36th edition and Barcelona in 2024 for the 37th. Now the Cup is preparing to write a new page in its history in Italy. Indeed, in 2027 it will be Naples that will host the 38th edition of the competition, while the run-up has already begun with the preliminary regattas held in Cagliari from May 21-24, 2026.
The arrival of theAmerica’s Cup in our country represents much more than a prestigious sporting recognition. In fact, the event is capable of generating important economic, tourism and industrial spin-offs, attracting investment, highly specialized professionals and extraordinary international visibility. It is precisely in such a perspective that the Italian legislature, expressly recognizing the special importance of the event, introduced with Decree-Law No. 38 of March 27, 2026, converted into Law No. 88 of May 22, 2026, a specific package of tax benefits intended for teams, organizational structures and professionals involved in the competition .
The new tax regime introduced by Decree Law 38/2026
As just mentioned, with the conversion into law of Decree-Law No. 38 of March 27, 2026, tax provisions dedicated to the 38th edition of theAmerica’s Cup in Naples were introduced.
The goal is clear: to facilitate the holding of the competition as has been done in other countries, which have hosted the event over the years, by facilitating the establishment of foreign teams , organizational structures and highly specialized professionals accompanying the event.
The choice does not represent an absolute novelty. The introduction of favorable tax regimes at events of international importance had already been observed with theMilan Expo edition in 2015. Likewise, on the America’s Cup side, already on the occasion of the 37th edition in Barcelona in 2024, Spain had provided a system of tax incentives aimed both at the companies involved in the organization of the Cup and at the individuals who worked there. The Italian Legislature, following in the footsteps of the Spanish one, has introduced similar measures to encourage international investment and expertise to settle in Italy, both with regard to the taxation of companies and with regard to individuals from abroad involved in the event.
No Ires and Irap for Cup activities
The first measure, it said, concerns companies with registered offices in Italy, established in 2026 by the organizing body or teams participating in the competition.
For these entities, there is an exemption from IRES and IRAP with respect to activities carried out between January 1, 2026 (thus including the preliminary regattas held in Cagliari) and December 31, 2027, as long as they are directly and exclusively related to participation in theAmerica’s Cup. The benefit also extends to permanent establishments set up in Italy in 2026 by foreign teams to manage activities related to the event.
In practical terms, the legislature wished to prevent the opening of operational bases, logistics centers, technical offices or organizational facilities in our country from entailing a tax burden that would make the presence of foreign teams less easy.
The favorable treatment for foreign technicians, athletes and professionals
The second level of benefits, on the other hand, affects individuals.
In particular, in order to encourage the involvement of highly qualified personnel, the rule provides that income from employed, assimilated and self-employed work received in tax years 2026 and 2027 by individuals who are not tax residents in the territory of the state for activities carried out for the benefit of the participating organization or teams is fully exempt from Italian taxation. This is a simplification with respect to the application of Article 15 (2) of the OECD Model Convention implemented in the Treaties entered into by Italy.
For those who, and conversely, should transfer their tax residence* to Italy, the legislature has provided-for the same time frame-an additional benefit: the fees received, related to the event, will contribute only 35 percent of their amount to the formation of taxable income. In other words, 65 percent will remain fiscally excluded from taxation.
This favorable regime is, by express regulatory provision, not cumulative with the optional tax regimes currently in force in Italy for individuals who transfer their tax residence here: in particular, the regime for so-called “neo-residents,” the regime for impatriate workers as well as that for teachers and researchers. It is therefore advisable to assess the convenience of adopting one or the other regime.
The legislature with the aforementioned facilities looks to the operational and international side of theAmerica’s Cup, which involves designers, engineers, composite material specialists, electronic technicians, meteorologists, data analysts, professional sailors and numerous other highly skilled figures from all over the world, by reducing or even eliminating the tax burden otherwise associated with participation in the event.
The tax side is flanked, however, by that of social contributions, which, as is well known, must be paid on the basis of the territoriality principle.
Here it appears that the Legislature has forgotten to regulate this aspect. It is, therefore, appropriate that foreign workers, coming from countries with which a social security agreement with Italy is in force, require a certificate of social security coverage (e.g., the A1 certificate for those coming from European countries, the IT/USA Form 4 for the United States, etc.). On this point, therefore, it is hoped that the Legislature will provide appropriate clarification.
An opportunity for the Italian boating industry
TheAmerica’s Cup has always been much more than a regatta. It is a laboratory of innovation in which advanced design, materials research, marine engineering, electronic systems and sustainability converge.
For Italy, and for Naples in particular, the 2027 edition represents an extraordinary opportunity to consolidate its role in the international nautical and marine industry scene.
The facilities introduced by Decree Law 38/2026 fit exactly into this perspective: creating a favorable fiscal environment capable of attracting skills, investment and technology, transforming the presence of theAmerica’s Cup from a mere sporting event to a lever of economic and industrial development for the entire country.
After all, winning theAmerica’s Cup challenge requires more than just a fair wind. Sometimes you also need a fiscal capable of blowing in the same direction.
Luca Valdameri and Martina Calissi
*Thefollowing are considered residents under Article 2, Paragraph 2 of Tuir: “For the purposes of income tax, persons who for the greater part of the taxable period, including fractions of a day, have their residence within the meaning of the Civil Code or domicile in the territory of the State or are present there are considered residents. For the purpose of applying this provision, domicile means the place where the person’s personal and family relationships are primarily developed. Unless proven otherwise, persons registered for the greater part of the tax period in the registries d he resident population”
