Napoli's Title Race Puts British Workers in Europe Back in the Spotlight

Napoli have clinched their fourth Serie A title, ending Inter Milan's challenge in a season defined by two British-connected players: Scott McTominay, the Scottish midfielder who left Manchester United in 2024, and Kevin De Bruyne, the former Manchester City captain. Their performances — both scored in a 4-0 win against Cremonese — have put British workers in European football firmly back in the UK spotlight. But the questions their careers raise about working in the EU after Brexit extend far beyond football.

What Changed After Brexit for British Workers in Europe?

Before 31 January 2020, British nationals working in EU countries enjoyed freedom of movement — the right to live and work in any EU member state without a visa or work permit. That right ended when the UK left the European Union.

British nationals who were already lawfully residing and working in an EU member state before 31 December 2020 retain protected rights under the Withdrawal Agreement. Scott McTominay left the Premier League in the summer of 2024, after this deadline, meaning his employment in Italy is governed by post-Brexit arrangements — not the transitional protections.

For UK nationals taking up employment in Italy from 2024 onwards, the process involves:

• Applying for a Nulla Osta (work authorisation) through the Italian immigration office, typically sponsored by the employing organisation
• Securing a national visa (type D) at an Italian consulate in the UK before arriving
• Registering with the Anagrafe (local registry) and obtaining a Codice Fiscale (tax identification number) upon arrival

For Napoli's football department, this is an established administrative process. For a UK professional relocating to Italy to take an ordinary job, navigating it without professional guidance can lead to delays, incorrect tax status, or complications with Italian social security contributions.

Tax Residency: Where Do You Pay?

Tax residency is one of the most consequential — and most misunderstood — aspects of working abroad as a British national. Many UK workers assume that leaving the country automatically ends their UK tax liability. This assumption is frequently wrong.

HMRC's Statutory Residence Test (SRT), introduced in 2013, determines tax residency through a combination of days spent in the UK, ties to the UK (family, property, work), and the nature of employment. Working full-time abroad does not automatically make you non-resident for UK tax purposes if you continue to visit the UK regularly, retain a home there, or have significant UK income from other sources.

For a Scottish footballer employed in Naples:

• If they spend fewer than 16 days in the UK in a tax year, they are automatically non-resident
• If they spend 16-45 days and have three or more UK ties, they may be resident
• Italian income will be taxed in Italy under Italian employment law
• The UK-Italy Double Taxation Agreement prevents the same income from being taxed twice, but the mechanics require careful management

Under Italian rules, workers who have not been tax resident in Italy for the previous two years and who take up employment that is genuinely performed in Italy may qualify for a preferential regime — the regime dei neo-residenti per lavoratori impatriati — reducing their Italian taxable income significantly. However, this regime must be formally elected within the first tax return and is not automatic.

Social Security Contributions: A Separate Issue

Beyond tax, social security contributions are a distinct concern. Under the EU-UK Trade and Cooperation Agreement, the UK and EU negotiated a general framework, but each member state has bilateral elements that affect where national insurance and equivalent contributions are payable.

British workers in Italy who are employed by an Italian entity will generally contribute to INPS (the Italian national social security institution) rather than UK National Insurance. This means their entitlement to UK State Pension accrual pauses during the period of Italian employment unless they make voluntary Class 3 contributions to HMRC — something many workers overlook.

According to GOV.UK guidance on working abroad, UK nationals should check the specific arrangements with HMRC's international team before relocating, as the rules differ between employed and self-employed status and between different EU member states.

Employment Contracts and Governing Law

One practical concern that often surfaces only after a dispute arises is which country's employment law governs the contract. Italian employment law differs from UK law in several important respects:

• Notice periods in Italy are typically governed by the CCNL (collective labour agreement) relevant to the industry, not by the employee's individual contract
• Italian courts have jurisdiction over employment disputes where the work is predominantly performed in Italy, regardless of what the contract says
• Non-compete clauses are enforceable in Italy but subject to strict proportionality and compensation requirements that differ from UK practice

For British professionals taking senior roles at Italian companies, understanding these differences before signing is considerably less expensive than challenging them after a dispute.

What Should UK Workers Do Before Relocating?

Whether you are a footballer, a finance professional, a software engineer, or a hospitality worker considering an Italian employer's offer, the practical steps are:

1. Obtain a formal work authorisation through your prospective employer before arriving
2. Check your UK residency status under the Statutory Residence Test with a qualified tax adviser
3. Review whether voluntary UK National Insurance contributions make sense for your circumstances
4. Have your employment contract reviewed by a solicitor familiar with both UK and Italian employment law
5. Understand your rights if the role does not materialise as promised — including any right to repatriation costs

McTominay's success at Napoli has inspired considerable interest among UK fans and professionals alike. The route is legally navigable — but it requires preparation that most relocation packages from smaller employers may not provide automatically.

An ExpertZoom legal or tax specialist can review your international employment contract, advise on your UK tax residency position, and help you understand your rights as a British worker in the EU.