Italy Clarifies VAT Compliance Relief for Non-Profit Amateur Sports Organizations

Summary

The Italian Revenue Agency has confirmed that qualifying non-profit amateur sports associations and companies may opt out of VAT invoicing and record-keeping for certain exempt services closely connected with sport or physical education, even though the exemption is contained in separate sports legislation rather than article 10 of the general VAT decree. [agenziaent…ate.gov.it], [fiscooggi.it]
The relief applies to eligible exempt sporting services supplied to persons participating in sport or physical education. It does not remove compliance obligations for taxable activities, and application of the option may restrict the organization’s ability to deduct input VAT attributable to exempt transactions. [agenziaent…ate.gov.it], [vatupdate.com]
The transfer of an athlete’s contract by a non-profit amateur sports organization to a professional club remains subject to VAT. According to the authority, the purchasing club, rather than the athlete engaged in sport, is the recipient of the contractual rights, so the required objective link with sporting participation is absent. [fisg.it], [federkombat.it]

Article

The Italian Revenue Agency published Circular No. 7/E on 7 August 2026, providing extensive guidance on the tax treatment of amateur sports entities and sports workers following the reforms introduced by Legislative Decree No. 36/2021. Among other matters, the circular addresses two practical VAT questions for non-profit amateur sports associations and companies, commonly referred to as ASDs and SSDs. [agenziaent…ate.gov.it], [fiscooggi.it]

The first concerns the option under article 36-bis of Presidential Decree No. 633/1972. That provision allows taxable persons carrying out qualifying VAT-exempt activities to obtain relief from invoicing and VAT record-keeping requirements, subject to specified exceptions. Uncertainty arose because the wording refers to transactions exempt under article 10 of the VAT decree, while certain sports and physical education services are currently exempt under article 36-bis(1) of Law Decree No. 75/2023.

The authority concluded that eligible sports organizations may nevertheless exercise the option. Both national provisions are intended to implement the exemption for certain services closely connected with sport or physical education under article 132(1)(m) of the EU VAT Directive. The authority therefore considered the common EU-law basis and purpose sufficient to bring the sports exemption within the compliance relief.

Organizations should not treat the option as a general release from VAT administration. Taxable transactions remain subject to the ordinary invoicing, recording and reporting requirements. In addition, the organization should assess the consequences for input VAT recovery, including the allocation of costs between exempt and taxable activities and any applicable deduction restrictions or pro rata calculation.

The circular separately addresses transfers of athletes’ contracts to professional clubs. The authority concluded that such transfers are not exempt sporting services. Although the supplying ASD or SSD may satisfy the non-profit condition, the service is supplied to the acquiring professional club, which obtains the right to use the athlete’s services. It is not supplied to the person participating in sport or physical education.

This distinction is consistent with the strict interpretation of VAT exemptions reflected in the Court of Justice of the European Union’s judgments in Cases C-488/18, Golfclub Schloss Igling, and C-253/07, Canterbury Hockey Club and Canterbury Ladies Hockey Club. Sports organizations should therefore separate participation-related services from transfers, sponsorship, advertising and other commercial activities when configuring VAT codes and invoicing processes.

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