Italy Tax Agency Clarifies Tax Treatment of Carried Interest in Managerial Share Plans

The Italian Revenue Agency Sept. 29 issued Answer No. 256/2025, clarifying the tax treatment of managerial investment plan income. The taxpayer, an employer, allowed managers to subscribe to shares in the parent company. Some share classes received preferential dividend treatment compared to other classes of shares. The taxpayer sought clarification as to individual income tax treatment for the share subscribers. Upon review, the Tax Agency clarified that: 1) all of the investment commitments were entitled to an actual disbursement of at least 1 percent of the total investment; 2) the enhanced proceeds accrued only after all participants received an amount ...