Fiscal decree

Transition 5.0: Only 35 per cent of the bonus due to companies in the queue

Only the tax credit for investments in capital goods, increased by the expenses incurred to fulfil certification obligations, will be covered. Confindustria: very penalising for companies, confidence damaged

by Carmine Fotina

 Valentin - stock.adobe.com

5' min read

Translated by AI
Versione italiana

5' min read

Translated by AI
Versione italiana

The Council of Ministers of 27 March declared a mockery, perhaps unprecedented, for the industrial companies that had counted on innovation incentives. The 'exodus' of the 2025 Transition 5.0 plan, i.e. the companies that had duly submitted 7,417 projects and were on the waiting list due to the exhaustion of resources, will only receive 35% of the requested tax credit. In practice, one-third of the allowance due. In the best case scenario, in which about 80% of the companies fall, the actual tax credit will therefore be 15.75% (i.e. 35% of the 45% maximum rate for the most energy-efficient projects). Otherwise, it will be 14% or 12.25%. An allowance that is even lower than the one provided for investments in the old Transition 4.0 plan.

Capital goods only

Not only that. Only the tax credit for investments in capital goods will be covered, increased by the expenses incurred to fulfil the certification obligations. Investments for energy management systems and installations for energy from renewable sources for self-consumption are excluded. This is a further detriment for all those companies that had been incentivised to prefer the purchase of high-efficiency photovoltaic modules - mainly produced by 3Sun of Catania (Enel group) - over products made in China, which guarantee lower energy savings but are at least twice as cheap.

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Communication

It will be the GSE (the energy services manager) that will inform the interested parties of the tax credit that can be used, notifying the Revenue Agency in advance,

Employed 537 million

For this remedial intervention included in the tax decree, which falls far short of the expectations and assumptions that had been circulating in recent months (including that of repairing the damage with an enhanced version of the 4.0 bonus), the government will use only 537 million of the 1.3 billion fund that had been allocated in the budget law. The 537 million represents 35 per cent of the total tax credit claimed by companies in the queue and regularly meeting the technical requirements, i.e. 1.65 billion.

Promises from Palazzo Chigi

One can foresee at this point the disappointment of the business associations that had long relied on the reassurances of the Ministry of Enterprise and Made in Italy and the Ministry of the Economy that all demands would be met. In the communiqué issued after the council of ministers, Palazzo Chigi announces 'the intention to start a round table with the production categories concerned in the coming days. The aim is to evaluate, when the decree is converted, any additional resources that become available, also in the light of the comments that will be received on the order of priority for their use'. A rather cryptic communication that does not clarify why at least the entire 1.3 billion dowry allocated in the budget law has not been used. One of the hypotheses circulating in recent weeks is that the remaining resources of that fund could constitute an emergency reserve for possible support measures for companies, for example on energy costs, in the face of the crisis in the Middle East.

Extremely high depreciation: stop made-in-EU clause

Turning to the tax decree, an amendment was also approved regarding the new Transition 5.0 Plan, the one that concerns investments made from 1 January 2026 to 30 September 2028 and provides for a tax hyper-amortisation as an incentive instead of a tax credit. The decree deletes the 'made in Europe' territorial requirement, which appeared highly controversial from the outset because it would have severely limited the capital goods (tangible and intangible) that can be purchased with the benefit of the hyper-amortisation. This was a correction that had been awaited for several months and that effectively blocked the process of the implementing decree that the Ministry of Enterprise and Made in Italy had sent to the Ministry of the Economy at the beginning of January. The repealed clause bound purchases only to goods produced in the states of the European Union or of the Agreement on the European Economic Area, cutting out non-EU suppliers offering products that were in any case competitive, such as those from the United States, Japan or Korea, as well as those from China, which immediately seemed to be the real target of the initiative. The removal of this constraint entails a very significant cost burden, estimated at around EUR 1.4 billion over 10 years. The total cost of the new Transition 5.0 plan thus rises to about 9.8 billion until 2035. After the removal of the territorial requirement, announces the Ministry of Enterprise, 'the new implementing decree will be prepared in the coming days with the necessary modifications'.

Orsini: on Transition 5.0 urgent table with Giorgetti, Urso, Foti

"We learn with great concern about the lack of resources allocated to the exodus workers linked to the Transition 5.0 plan. This is a crucial issue that cannot be postponed or downsized," warned the president of Confindustria, Emanuele Orsini. "This is why we urgently call for the opening, as early as next week, of a discussion table with the Minister of the Economy Giancarlo Giorgetti, the Minister of Enterprise and Made in Italy Adolfo Urso, and the Minister for European Affairs Tommaso Foti." And again: 'The trust between institutions and the production system cannot be broken. A clear, rapid and coherent response to the commitments made is needed on this point'

Confindustria: highly penalising for companies, damaged confidence

 "The tax decree published yesterday in the Official Gazette introduces very penalising provisions for companies that booked the 5.0 tax credit between 7 and 27 November 2025. The text provides for a 65% cut in the tax credit claimed. The measure also excludes investments in renewable energy sources, in particular higher-efficiency photovoltaic systems registered with Enea, which companies have been induced to purchase,' said Mario Novicelli, vice president for industrial policies and Made in Italy at Confindustria. The decision 'heavily penalises companies that have completed substantial investments in 2025 and will face further liquidity problems at an already particularly complex time'. In November, he recalls, 'we had been reassured by ministers Giorgetti, Foti and Urso that the so-called "exodus" companies of the 5.0 with congruous projects would have had access to the subsidy'. The fact "of not being able to rely on the government's regulations and declarations deeply undermines the trust of companies in institutions and incentive measures and discourages those who would like to continue to do business in Italia. Finally, we learn from Mimit's declarations this morning that other resources would be found for the hyper-amortisation: our answer is: first pay the debt with the 5.0 companies".

Criticism also comes from AssoEsco, the association of Esco (energy service companies), which, with president Giacomo Cantarella, asks the government for 'urgent intervention in the face of yet another act of great uncertainty'.

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