Immobile finished off an exchange with Adam Marusic with one touch midway through the first half of a 3-1 loss at Napoli.

Juventus striker Gonzalo Higuain also scored 36 in 2015-16 while with Napoli, improving by one goal on the previous mark set by Gunnar Nordhal 66 years earlier.

Higuain scored only three of his goals from penalties in his record season while Immobile converted 14 spot kicks in 2019-20 - almost 40 per cent of his total goals.

Cristiano Ronaldo, who finished second on this season's scoring chart with 31 to match Juventus' club record, had 12 penalties.

The plethora of penalties was a product of a rule calling for involuntary handballs to be classified as fouls.

The rule is expected to be revised for next season.

Immobile also sealed this season's European Golden Shoe award.

Goals from Fabian Ruiz, Lorenzo Insigne and Matteo Politano gave Napoli the win as they concluded the season seventh while Lazio finished fourth - having trailed champions Juventus by just one point when the season was suspended in March due to the coronavirus pandemic.

Inter Milan sealed second place with a 2-0 win over high-scoring Atalanta, who hadn't been held to a clean sheet since November.

Danilo D'Ambrosio scored with a header and Ashley Young found the target from outside the area in the opening 20 minutes.

Inter finished the season one point behind Juventus, who suffered a 3-1 loss to visitors Roma on Saturday.

Atalanta finished third for the second-straight season, four points behind Inter.

Ronaldo and strike partner Paulo Dybala were rested in Juve's home loss - with the Bianconeri focused on next week's Champions League return.

After Higuain's opener for the hosts, Roma struck back with a goal from Nikola Kalinic and two from Diego Perotti.

Still, it was a celebratory night for Juventus, who received the Serie A trophy after the game inside the empty Allianz Stadium.

Despite playing only half the season, Zlatan Ibrahimovic became the oldest player to score 10 or more goals in a single Serie A season.

Milan accounted for Cagliari 3-0 and will play in next season's Europa League qualification round.

Meanwhile, Sampdoria drew 1-1 at already-relegated Brescia.

The Italian top flight concludes on Sunday with five matches including home clashes for 17th-placed Genoa and 18th-placed Lecce who are battling to avoid the drop.

Australian Associated Press