designed primarily with large-scale distribution and standard catering activities in mind, and only marginally intersect with the fine dining segment. A targeted extension of these provisions to Michelin-starred restaurants could be envisaged, for example by allowing enhanced deductions for documented donations, credits for investments in technologies aimed at reducing waste and energy consumption, or differentiated VAT regimes for certified sustainable sourcing practices. In this way, fiscal law would not merely perform a redistributive or revenue-raising function, but would also operate as an instrument of governance capable of steering the behavior of high-end gastronomy toward ecological and social accountability. From a comparative perspective, it should be noted that several jurisdictions are already experimenting with fiscal mechanisms that reward compliance with sustainability standards. In France, fiscal allowances linked to training and heritage preservation increasingly dialogue with environmental imperatives; in certain Asian contexts, the recognition of Michelin restaurants has been explicitly connected to local policies aimed at sustainable tourism and resource efficiency. Embedding similar approaches within the Italian context would serve a dual purpose: on the one hand, enhancing the international credibility of Italian haute cuisine as a champion of environmental and social responsibility; on the other, creating a replicable model for the broader hospitality industry, in which the fiscal system functions as a catalyst for the translation of ESG principles into concrete managerial practices12. In sum, the alignment of fiscal policy with ESG criteria in the field of fine dining would allow Michelin-starred restaurants to consolidate their role not only as cultural and touristic icons, but also as laboratories of sustainable innovation. Such a perspective responds to the broader academic debate on the extrafiscal function of taxation, illustrating how the tax system can be mobilized tributaria internazionale, 2019, n. 4, CEDAM, p. 1015. 12 The term ESG, an acronym for Environmental, Social and Governance, was coined in 2004 in the publication “Who Cares Wins – Connecting Financial Markets to a Changing World”. Over the past years, this analytical framework has become increasingly significant in the investment process: considering environmental, social, and governance (ESG) issues as part of an investment strategy means acquiring greater awareness of the companies in which one invests. This is particularly relevant in the food sector, where ESG considerations intersect directly with issues of sustainability, public health, and cultural identity. From an environmental perspective, food production and consumption are closely linked to challenges such as climate change, biodiversity loss, and resource management. On the social side, the agri-food industry plays a crucial role in shaping dietary models, ensuring fair working conditions along supply chains, and supporting local communities. Finally, the governance dimension highlights the importance of transparent business practices, responsible sourcing, and compliance with food safety and sustainability standards. In this sense, integrating ESG principles into investment strategies in the food domain not only enhances risk management and long-term profitability but also contributes to fostering more sustainable and equitable food systems. 519 THE FISCAL DIMENSION OF STARRED RESTAURANTS
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