Messi is currently tax resident in Spain. However, he enrolled in the register of Italian citizens residing abroad (hereinafter, “AIRE”) in Recanati (Italy).

Should Messi decide to move to Italy and play for an Italian football club in Serie A (let's say Inter or Rome), he could benefit from the new Italian tax regime (in force starting from May 1st) designed for foreign tax resident workers that relocate to Italy from 2020.

His employment income (the income he would receive from the Italian football club) would be subject, for 5 years, to Italian personal income tax on a portion equal to 30% of the income getting a 70% tax exemption. 

Moreover, should he decide to play for an Italian football club in (and move his residence to) South of Italy (Naples or Lecce), the exemption from income taxation would be even higher: 90% exemption on the employment income!

Moving to Italy Messi would also have another tax option to mitigate his personal tax treatment. The 2017 Budget Law introduced specific tax provisions for HNWIs wishing to become tax resident in Italy. Italy’s tax regime provides for a substitutive tax on all foreign-sourced income of new Italian residents. 

Eligible individuals can opt for a one-off payment of €100,000 per year for a maximum of 15 years, regardless of the amount of income received. Remittances of foreign-sourced income in Italy do not trigger further taxation. However, in such a case, Italian-sourced income would be taxed under the ordinary tax regime (43% tax rate plus local taxes).

Why this tax regime may be interesting for Messi? Because a relevant stream of income for him may derive from the commercial exploitation of his image rights. For example, revenues from sponsorship contracts such as payments received by an American sportswear company for sponsorship activities carried out exclusively in Brazil and dividends paid from his “star company" could be treated as non-Italian income and taxed under the €100k "umbrella" taxation.