The new tax for companies: from the maxi IRES discount to tax credits, the requirements for paying less

Invest to reduce the tax burden. And seize the opportunities for corporate innovation and reorganisation. The changes introduced in the parliamentary procedure of the manoeuvre and the full operativeness of the Irpef-Ires decree (decree 192/2024), implementing the proxy, try to outline a new scenario for the business tax. They create the conditions for a change of pace at the intersection of budget law and tax reform.

The opportunity to lock in the bonus IRES rate, reduced to 20 per cent, is tied to a number of conditions: from reinvestment of profits to increased employment. But it is also an opportunity to push innovation, especially due to the link with Transition 5.0 investments, for digital and energy transformation. In this sphere, the manoeuvre has brought some adjustments that - while not extending the deadline for subsidised investments (the deadline remains 31 December 2025) - strengthen bonuses and simplify consumption reduction calculations: opening up a few more glimmers of hope, even if the mechanism is still characterised by many stakes and the risk of high compliance costs (reservations are at about 5% of the 6.23 billion Pnrr funds available).

Certainly, an unfair limitation would have been to prohibit cumulation with the tax credit for investments in the Special Economic Zone of Southern Italy and with other European subsidies. The green light came during the procedure: it is enough that the support does not cover the same cost shares as the individual investments of the innovation project and that the benefit does not exceed the expenditure incurred (a rule that also applies to the Transition 4.0 plan).

However, the attempt to boost the benefits must be framed, as mentioned, in the new tax framework drawn up by the Irpef-Ires decree. The long gestation of Decree Law 192, which began with the preliminary approval in the Council of Ministers on 30 April and ended with its publication in the 'Official Gazette' on 16 December (the last day for it to enter into force in 2024), allowed those involved to prepare and discuss the possible effects of the measures in advance.

There are at least two underlying trends. On the one hand, there is the aim of making the tax treatment of extraordinary transactions more homogeneous, for which the changes that have come about in recent years (especially those to regulate arrangements at risk of abuse of law) have ended up generating greater uncertainty and even slowing down arrangements that could have been more functional in increasing productivity and meeting the challenges posed by global changes. On the other hand, a further effort (perhaps not entirely decisive) to increasingly shorten the distances between accounting and tax data: enhanced derivation may prove to be the lever to make the work of professionals and business consultants more 'substantial'.