Italian Revenue Agency Issues Ruling that Stock Options Vested During Employment in Italy Remain Taxable in Italy

The Italian Revenue Agency (IRA) has issued Ruling No. 316 of 7 September 2020 regarding the tax treatment of stock option benefits received by an Italian tax resident but exercised following a change in tax residence. The ruling addresses a case involving an individual that worked for different offices of an MNE group in various countries. From January 2003 to August 2016, the individual was employed at the group's headquarters in Italy, during which time the individual received stock optio…