Italy Tax Agency Clarifies Taxation of Income Earned by Resident Seafarers Working on Foreign-Flagged Ships

The Italian Revenue Agency Jan. 20 issued Letter No. 10/2026, clarifying the taxation of income earned by resident seafarers working on foreign-flagged ships. The taxpayer, a resident seafarer, completed multiple embarkations on foreign-flagged ships between 2022 and 2024. The taxpayer argued that his income earned in 2024 should qualify for an exemption from Italian tax due to exceeding the requirement of working 183 days abroad within an overlapping 12-month period. Upon review, the Tax Agency clarified that: 1) the 183-day requirement needed to be verified for each specific employment contract, not merely across multi-year activities; 2) the taxpayer couldn’t benefit ...