Tax Pills

Decree No. 19/2024 and the implementing provisions of the Nrrp (National recovery and resilience plan), published in the Official Gazette No. 52 general series, on March 2, 2024, have introduced a new tax credit for investments made in the 2024-2025 period in connection with the 'Transition 5.0 Plan.' The aim of this measure is to support the digital and energy transformation of enterprises. Particularly, the tax incentive is regulated by Article 38 of the legislative decree.

The bonus is designed to benefit companies that invest in tangible or intangible capital goods 4.0 or purchase goods necessary for self-production and self-consumption from renewable sources. Additionally, also expenses for training staff in green transition skills can benefit from this fiscal measure.

Beneficiaries and requirements for accessing the tax credits
All Italian-based companies and organizations, regardless of legal form, economic sector, size, or tax regime adopted for the determination of business income, can benefit from the contribution. The cases of exclusion are listed in detail, including the state of voluntary or compulsory liquidation of the company.  The bonus is granted for new investments made in the 2024-2025 biennium in production facilities located within the territory of the State, yet the innovations implemented must result in a reduction of the energy consumption of the production unit of at least 3%, which increases to 5% if calculated on the process planned for the investment.

Tax credit calculation rates
The bonus works as follows: 35% for investments up to 2.5 million euros, 15% of the expenditure for investments exceeding 2.5 million euros and up to 10 million euros, and 5% of the expenditure for investments exceeding 10 million euros and up to the maximum limit of 50 million euros of eligible costs per year for each beneficiary company. Furthermore, the tax credit increases and can reach up to 40% and 45% in case of a reduction in energy consumption of more than 6% and 10%, respectively. Savings are calculated annually based on the previous year's performance. For new businesses, average annual energy consumption is taken into account, referring to a counterfactual scenario.

Stefano Latini

It is the first step in the direction of a revision of tax rules under the banner of simplicity. Indeed, the public consultation of the new Consolidated Texts, drafted by the Internal Revenue Service in implementation of the provisions of the enabling act for Tax Reform, opens today and will continue until May 13. This is the beginning of a path whose landing place is the systematization of tax law through the determination of fixed points that will restore certainty to the intricate tax legislation that is constantly evolving. 

Nine new Consolidated Texts are available for consultation 
The proposed Consolidated Texts are organized by areas of expertise ranging from income taxes to VAT, and from collection to reliefs. Below is a list by individual topic: Income Taxes (link to pdf of the Consolidated Text); VAT (link to pdf of the Consolidated Text); Registration Tax and Other Indirect Taxes (link to pdf of the Consolidated Text); Minor Excise Taxes (link to pdf of the Consolidated Text); Compliance and Assessment (link to pdf of the Consolidated Text); Administrative and Criminal Penal Sanctions (link to pdf of the Consolidated Text); Tax Justice (link to pdf of the Consolidated Text); Payments and Collection (link to pdf of the Consolidated Text); Tax Concessions and Schemes for Particular Sectors. (link to pdf of the single text). 

The purpose of the initiative 
The goal of such an unprecedented effort is the reorganization of the more than 900 tax laws in terms of form and substance in order to ensure legal certainty and clarity in their application.

How to send contributions 
Interested parties have until May 13, 2024 to send their comments and proposed amendments, according to the scheme: topic, paragraph of the selected Consolidated Text, comments, contribution and purpose. At the end of the consultation, the Agency will publish the received contributions (except those containing request for non-disclosure) and evaluate them in order to possibly incorporate them into the final version of the document. 

Stefano Latini