Foreign social security contributions deductible from conventional salaries

The Italian Tax Authority, through the recent Ruling no. 5/2026, has provided a significant clarification in favor of Italian tax-resident employees working abroad regarding the possibility of deducting mandatory social security contributions paid in the foreign State when income is determined on the basis of conventional salaries, a preferential tax regime reserved for employees who, despite being tax-resident in Italy, perform their work activities abroad for more than 183 days per year. For these individuals, taxable income is indeed determined on a lump-sum basis according to specific ministerial tables, rather than on the actual remuneration received.

Specifically, the Authority, aligning itself with the orientation of the Court of Cassation (judgment no. 17747/2024), has confirmed, after years of litigation, the relationship of specialty, and not of hierarchy, between the rules on the determination of individual income categories (art. 51 TUIR) and those on the determination of total aggregate income (art. 10 TUIR). In particular, social security and welfare contributions paid in compliance with statutory provisions, as resulting from the certification issued by the employer, if they are not deductible in the determination of the category income (because they are excluded by art. 51, paragraph 8-bis), become automatically deductible from the total aggregate income pursuant to art. 10, paragraph 1, letter e).

Operationally, the contributions paid abroad resulting from the employer's certification can be indicated in line E21 of Form 730/2025 (or Section RP of the "Modello Redditi")

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