Superbonus, fewer constraints for materials in the Sal

Count only supplies of materials accompanied by an asseveration of a technician, proving the presence on site and subsequent installation. This is the response that is taking shape to remedy the audits initiated by the Guardia di Finanza and the Agenzia delle Entrate on the superbonus salaries already closed in past years. A response that the government has espoused, giving the go-ahead to an order of the day approved in the Chamber (first signatory, Erica Mazzetti of Forza Italia).

The problem arises from a number of audits started in recent months to challenge superbonus salaries that have already been closed and for which in many cases the relevant tax credits have already been settled. At various stages - it should be recalled - upon reaching a certain stage of progress, the rules on the former 110% have linked quite significant effects. For example, at the end of 2022 the superbonus had been extended only for houses able to prove 30% progress by a certain date. The line taken in most cases was that materials delivered to the building site could be counted in the Sal. A practice that, locally, several revenue offices are now beginning to challenge.

"Numerous Sal's," recalls the agenda, "were calculated with the incorporated footings (about half according to some assessments), and deductions already used or credits transferred were based on them. Changing the interpretation on the fly 'could generate significant problems both for taxpayers (who might have to return the incentives) and for companies/professionals/credit institutions (who might be held jointly and severally liable)'. Moreover, the Cgt of Rieti recently expressed itself in the direction of a calculation that also includes materials that are only delivered (sentence no. 18/2025).

Now the bill calls for clarity and commits the government to assessing 'further initiatives, including regulatory ones, aimed at resolving the tax issue set out in the introduction, applying uniform criteria throughout the country' and clarifying that 'supplies of materials a piè d'opera may be accounted for in the progress of works (Sal), provided that such supplies are, through affidavit issued by the qualified technician, available to the beneficiary at the site of the subsidised intervention on the date of the progress of works and that they have subsequently been put in place'. Therefore, it will be necessary to armour the Sal with the asseveration of a technician, which proves the arrival of the materials at the building site before the terms fixed by the Sal and, subsequently, their installation. Only in this way can they be counted in the state of progress.

'With my order of the day,' Mazzetti explained, 'I committed the government to solving this problem according to uniform criteria throughout the country, providing for a non-retroactive application of the new tax office approach. In this way,' he concludes, 'we have provided families and businesses, particularly those thrown into despair by requests for the return of up to 250% of the subsidised sums, with an initial tool to counter claims that Forza Italia considers arbitrary both in substance and method.