Thesis title: PROFILI GIURIDICI E TRIBUTARI DEI NON FUNGIBLE TOKEN (NFT): ANALISI E PROSPETTIVE DI RIFORMA
The dissertation provides a systematic analysis of the taxation of Non-Fungible Tokens (NFTs), examining their legal nature and both direct and indirect tax implications within Italian, European, and international frameworks. NFTs, as unique digital certificates recorded on blockchain, raise fundamental issues of legal classification that directly affect the constitutional principles of tax legality and ability to pay. The lack of an explicit legislative framework has led to interpretative uncertainty and extensive analogical applications, potentially infringing the constitutional tax legality principle. The research develops a coherent theoretical and practical framework for NFT taxation, based on the principle of substance over form, emphasizing the actual economic and legal function of the token. After analysing direct and indirect taxation, the fiscal treatment of NFT marketplaces, and comparative experiences (OECD, MiCA, DAC8, CARF), the study concludes that a specific legislative intervention is essential to differentiate NFTs from cryptocurrencies, ensuring legal certainty, tax neutrality, and systematic coherence in the digital era.