Taxation of Deferred Remuneration in Cross-Border Employment Scenarios: Insights from Ruling Nos. 199/2025, 98/2025, 81/2025 and 12/2025

The Italian tax authorities (ITA) have recently issued four rulings – Nos. 199/2025, 98/2025, 81/2025 and 12/2025 – on the domestic and treaty treatment of deferred remuneration in cross-border employment. Ruling Nos. 98/2025 and 12/2025 reaffirm an accrual-based allocation based on where the work was physically performed, irrespective of subsequent changes in residence. By contrast, Ruling No. 199/2025 – revisiting the fact pattern of Ruling No. 81/2025 – marks a decisive shift back to the pre-2023 “residence-at-payment” approach seen in earlier stock option cases. This note outlines each ruling, highlights the tension within the ITA’s reasoning and considers practical implications for employers and internationally mobile workers.