Italy Tax Agency Clarifies Tax Treatment of Income Related to Holding of Warrants

The Italian Revenue Agency Oct. 1 issued Letter No. 258/2025, clarifying the tax treatment of income related to the holding of warrants. The taxpayer, a company, adopted an incentive plan that involved issuing warrants to selected managers and employees, allowing them to subscribe to new special category shares. The taxpayer sought clarification on whether the income derived from the warrants qualifies as financial income for tax purposes. Upon review, the Tax Agency clarified that: 1) the subscription of warrants being open only to managers who have an employment or similar relationship with the taxpayer, and the taxpayer’s broad discretion in ...