5.0 tax credits, for those in the queue relegated to the 4.0 bonus
Tax credits. This is the likely effect of the government amendment allocating 1.3 billion. Alternatively, the transition to the new hyper-amortisation, which, however, will not start until February
Another bitter surprise looms for companies that were counting on tax credits from the Transition 5.0 plan for 2025. The government amendment to the draft budget law, in fact, finds an additional 1.3 billion to meet outstanding applications, but in reality referring to the old Transition 4.0 plan, which provides less advantageous tax breaks.
In practice, the looming mechanism, barring further corrections, should result in those on the waiting list sliding from the 5.0 bonus to the 4.0 bonus. A de facto demotion. It is likely to be another mockery after it was abruptly announced on 7 November that the Transition 5.0 ceiling, originally EUR 6.23 billion under the NRP, would be closed to EUR 2.5 billion, well ahead of the original deadline of 31 December 2025. Reservations were nevertheless left open until 27 November and the projects on the waiting list reached approximately EUR 1.8 billion. The government then intervened with a decree-law that only allocated 250 million. Although it will have to be understood how many companies will communicate the actual completion of investments by 28 February, it is expected that the queue will exceed the 1.3 billion that the government managed to identify within the framework of the reshaping of the NRP. Among other things, it should be considered that the bookings for Transition 4.0 will go on until 31 December and that the ceiling, set in this case at 2.2 billion, has also been exceeded for this measure (at the moment, however, savings of about 200 million would have accrued).
The decision to finance 4.0 instead of 5.0, under the direction of the State Accounting Department, was dictated first and foremost by the fact that the 5.0 tax credits, by virtue of Eurostat rules, would have an impact on the deficit concentrated in the year in which the investment was made. The spreading of the deficit effect over several years had instead been granted to Italy, as an exception, for the 4.0 scheme because it had already been introduced before the new Eurostat guidelines came into force. Now, as mentioned, it is highly likely that the backward slide will occur for those who have booked and, between the two instruments, have exercised the option for the 5.0. The difference, which is not insignificant, lies both in the management of the investment project, as 5.0 compared to 4.0 also includes energy efficiency targets, and of course in the size of the benefit. Transition 4.0 allows access to a 20% tax credit (for investments up to 2.5 million), decreasing as expenditure increases: 10% over 2 million and up to 10 million and 5% over 10 million and up to 20 million. The 5.0 in force this year was decidedly more advantageous: 45% bonus for investments up to 10 million with maximum energy savings achieved. It goes without saying that the Treasury's decision to cover pending projects no longer with the 5.0 but with the 4.0 means a lower outlay in terms of coverage. In the meantime, the Ministry of Enterprise and Made in Italy (Mimit), which manages the plan, is studying possible alternative solutions. One, which will go through a further amendment to the manoeuvre, is the possibility for 'downgraded' companies to opt alternatively to enter the new Transition 5.0 plan, the one that from 1 January 2026 will replace the tax credit with the hyper-amortisation. Here too, however, some thought must be given. The government amendment has yes guaranteed time certainty for the planning of investments, which can now go up to September 2028, but in other respects it has turned out to be pejorative. The surcharge for green transition expenditure has been cancelled (so the hyper-amortisation will be a maximum of 180 per cent and no longer 220 per cent), a 'made in Europe' clause has been inserted that will complicate purchases, and the number of photovoltaic modules eligible for incentives has been restricted. Furthermore, despite expectations, the provision for an implementing decree has been confirmed. The Mimit will be ready in a few days, but the measure will still have to go to the Ministry of the Economy for consultation and then to the Court of Auditors for examination. In short, the start of the plan will slip by at least a month compared to 1 January 2026. With a gap between the old and the new plan.
