The map

Software: a mix of incentives, but the cloud is off the table for now

The accelerated depreciation scheme, which comes into effect on Friday, adds to the range of sector-specific measures but does not apply to web-based solutions

by Giuseppe Giordano, Umberto Mazzucco, Ranieri Villa

15 June 2026

3' min read

Translated by AI

Versione italiana

3' min read

Translated by AI

Versione italiana

A mosaic of incentives to which the latest piece has just been added. This is an overview of the measures currently in place to support investment in software and digitalisation of Italian businesses.

The most recent addition is the hyper-depreciation scheme, for which applications have been open since 12 noon last Friday, although the scheme excludes software as a service (SaaS), that is, in practice, solutions whereby, instead of installing software on their own systems, users access the software via the internet by paying a subscription fee. But let’s take it one step at a time.

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The Italian context

According to Eurostat data, in 2025 only 16.4% of Italian businesses were using artificial intelligence, compared with 26% in Germany and over 40% in Nordic countries such as Denmark and Finland. The OECD reports that Italian investment in intangible assets – software, data, research and development – remain among the lowest in the eurozone, whilst in advanced economies real investment in software has tripled since 2008, compared with aggregate growth of just 12 per cent for machinery. Productivity growth has shifted from physical assets to intangible assets, with the result that value no longer stems solely from the machine, but from the software that makes it ‘smart’.

Non-capitalisable rent

In this context, the hyper-depreciation scheme reintroduced by the 2026 budget is, on paper, an attractive incentive to support investment in technological capital goods: an increase in the acquisition cost of up to 180% for investments, open to all businesses, across all sectors and of all sizes, regardless of location, with no calls for applications or ranking lists, and applied in the tax return as a reduction in taxable income.

As mentioned, however, the scheme currently excludes software as a service. Technically, SaaS subscription fees cannot be capitalised as intangible assets: they are operating costs charged to the profit and loss account, and super-depreciation applies exclusively to depreciable assets.

The implementing decree extends the tax relief to assets acquired under finance leases, but not to subscription fees. The accounting rationale is sound. However, major international vendors have moved away from the model of perpetual on-premises licences. Today, artificial intelligence, cybersecurity, predictive monitoring and supply chain management are all delivered on a subscription basis. Software as a Service accounts for around 80 per cent of the cloud market.

This is not a new issue, and, moreover, it has already been resolved in the past. In fact, in 2017, the Italian Revenue Agency’s Circular 4/E had excluded SaaS from the Hyper-amortisation 4.0 scheme on the same grounds. The legislator subsequently intervened with the 2019 Budget Act (Law 145/2018, paragraph 229), allowing cloud subscription fees to be included among eligible expenses ‘on an accrual basis’; this approach was reaffirmed by Circular 8/E of 2019 and remains in force until 31 December 2024.

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Other measures

As mentioned, those seeking alternatives will find a system structured according to target groups and objectives (see the information sheet on this page). Simest – under its Digital Transition and E-commerce schemes – accepts cloud platforms and subscription-based software, but only as part of internationalisation projects.

The Mimit/Invitalia Digital Transformation programme offers a combination of a 10% non-repayable grant and 40% subsidised loan, and also covers software licence fees, but is open to SMEs only.

Smart&Start Italia provides funding for digital solutions through interest-free loans covering up to 80 per cent of eligible expenditure, but the scheme is available exclusively to innovative start-ups with business plans ranging from 100,000 to 1.5 million euros.

The ‘On-Oltre Nuove Imprese’ scheme covers business management software and applications involving AI, blockchain and the Internet of Things, with funding of up to 90 per cent of costs; however, it is aimed at small businesses established no more than 60 months ago, where more than half of the shareholders are under 36 or women.

However, none of these tools is accessible to any Italian business that wishes ‘merely’ to invest in cloud software or artificial intelligence to improve its productivity.

Hyper-depreciation could, in future, be the right ‘vehicle’ for supporting SaaS companies, thereby creating universal, automatic and technology-neutral support, in line with what already happened in 2019.