Budget Law

Tightening of compensations, under scrutiny 140 billion

New limits on contributions, withholding taxes and insurance premiums are coming. The expected revenue is minimal, but the intervention affects all bonuses from housing to accrued and still unused investments

Sergiogen - stock.adobe.com

3' min read

Translated by AI
Versione italiana

3' min read

Translated by AI
Versione italiana

At least EUR 140 billion, considering the credits already accrued and those that will be consolidated in the course of 2025. This is the gigantic perimeter within which, from 2026 and for the next few years, the narrowing of compensations, as set out in the Budget Law 2026, in the version that has just been approved by the Senate, will act. The bulk of this figure (over EUR 130 billion) concerns home bonuses accrued from 2020 and not yet used. The rest comes mainly from credits accrued in the course of 2025 through investments in the Special Economic Zone of Southern Italy and the Transition 4.0 and 5.0 plans.

The time schedule

The magnitude of these numbers explains the concern of businesses, overwhelmed by a double stranglehold that will also have a differentiated time frame. From January 2026 the amount of unpaid tax bills (for which there are no suspension measures in progress) will be halved from EUR 100,000 to EUR 50,000, which will trigger a freeze on the possibility of using credits for offsetting; in other words, above this threshold of unpaid tax bills there is a real risk of losing tax credits.

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From July 2026 comes the second, somewhat harsher squeeze: the scope of a clearing ban already in force since January 2025 for banks, financial intermediaries and insurance companies on home bonuses will be extended to all. Tax credits can no longer be offset against social security and welfare contributions, insurance charges, withholding taxes and substitute taxes.

These measures, contained in Article 26 of the Budget Bill, do not have a great impact in terms of financial effects: in total, when fully implemented, they are worth just under 300 million. The real value of the work, however, must be measured in terms of the effect on controls.

Objectives and Critical Issues

One of the key objectives of the Inland Revenue, in fact, is an increasingly in-depth analysis of tax credits, in order to avoid the use in F24 of benefits resulting from offences. By reducing the exit channels of these credits, the preventive control activity becomes more effective. An activity that, in the first nine months of 2025 alone, has led the Inland Revenue to discard 561 million euro and to suspend for further investigation approximately three billion euro for which, as the technical report to the manoeuvre explains, net of those already discarded, no attempts at compensation have been made.

The problem is that thousands of companies that have accrued (or will accrue) totally legitimate credits are caught in the pincer of this new squeeze. For them, restrictions are triggered that risk making these items difficult to dispose of. The most sensational case is certainly linked to the gigantic mass of home bonuses, generated since 2020, and still not used in F24. Currently, there are still over 130 billion euro in circulation, mostly linked to the superbonus (over 86 billion), but also relating to concessions such as the facade bonus (over 18 billion), the renovation bonus (13 billion) and the ecobonus (11 billion).

In addition to this mass of subsidies, there are also other tax credits, of a more limited amount but equally relevant for companies. Such as that for the Zes unica del Mezzogiorno, which for 2025 has an allocation of 2.2 billion. While, again in the current year, the resources available for the old 4.0 plan and those of the NRP for Transition 5.0 amount to almost 5.3 billion. The total of credits affected by the squeeze, therefore, may exceed 140 billion.

Companies penalised

The identikit of the enterprise most penalised by this intervention has above all two characteristics that, combined, could create an explosive mix: a high number of employees (and therefore many contribution payments to be made every month) and a low level of income, for example due to losses that reduce the amount of taxes to be paid. In this way, therefore, enterprises in difficulty or, paradoxically, those that have made investments may be doubly penalised.

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