From limits on offsets to advance submission: this is how the squeeze on bonuses
Over time, various mechanisms have been introduced to control disbursements
When in 2008 the then Minister of the Economy Giulio Tremonti introduced 'mechanisms of control to ensure the transparency and effective coverage of tax concessions', it was thought that the time of 'tax credits' was over forever. We refer to the compulsory reporting of expenses incurred for the tax credit for research and development and the procedures for 'blocking' the resources with consequent allocation (Article 29 of Decree-Law 185/2008).
However, the experience of the following years - from the new versions of the R&S credit to the building bonuses - has shown how the criticalities of this instrument were far from being overcome: both in terms of uncontrolled expenditure for the Treasury and in terms of lack of transparency (and fraud risk).
The control mechanisms
Over the years, there have been several attempts to put a stop to this:
- theclick day, with the relative exhaustion of resources in just a few minutes;
- the booking with fixed resources to be divided up at the end of the year;
- the multiplication of thecommunications (prior, intermediate and subsequent) typical of the latest version of the Transition 4.0 and 5.0 tax credits, with the entry of the Gse;
- the limitation on the circulation of tax credits, introduced to curb the transfer of building bonuses;
- the lengthening of the number of annual instalments into which the amount is divided;
- the gradually strengthened limits on the 'spending' of tax credits in theF24 forms.
The return to the hyper-amortisation shows to a large extent how the 4.0 and 5.0 credit experience has also proved unsatisfactory from the legislator's point of view, and often also from the point of view of taxpayers grappling with complex and cumbersome procedures (in the near future, more verifiable mechanisms are to be hoped for from those directly concerned, and that there will be a rapid and unbureaucratic passage of information between the GSE and the Inland Revenue).
The Case of Transition 4.0 and 5.0
However, where tax credits are still used by the legislature, many of the limitations described above also remain.

