Employee Shares and Preferential Tax Regime: The Position of the Italian Revenue Agency in Ruling No. 147/2025 (Andrea Di Nino, Sintesi – Ordine dei Consulenti del Lavoro, July 2025)

Employee share plans are, to date, a tool frequently used by companies, particularly by listed corporations and large multinational groups.

Their growing popularity is undoubtedly due to the significant benefits they generate, despite the inherent complexities in their implementation. In fact, such plans can incentivize and foster employee loyalty by directly linking them to the company’s performance—sometimes more effectively than traditional tools.

Another factor that has certainly contributed to their spread is the preferential tax regime they may benefit from. It is precisely on this aspect that the Italian Revenue Agency has recently expressed its position through Ruling No. 147/2025. In this case, the tax authorities intervened following a query submitted by a company heading a multinational group, concerning a plan for the allocation of shares to employees—specifically, a so-called “broad-based” or “popular” share ownership plan—in order to clarify the conditions required for the application of the preferential tax regime provided under Article 51, paragraph 2, letter g) of the TUIR (Italian Income Tax Code).

Read the full version published in Sintesi, the journal of the Order of Labour Consultants.