With regards to the sponsorship expenses incurred in favor of sports clubs or associations (art. 90, paragraph 8, Law 289 of 2022) the Italian Supreme Court, dec. n. 38124 dated 12.30.2022, confirms its previous stance according to which the law provision at hand sets an absolute legal presumption of qualification of these expenses and their inherence which implies their deductibility from Corporate Income Tax (of course within the quantitative limits indicated by the same law provision).

Consequently, the position taken by the Revenue Agency with the assessment, according to which the absolute legal presumption does not cover the concept of inherence and the deduction expenses at hand can be denied, is disregarded.