ZES and logistics zones, the race for the last tax credits on demand
In 2024-25, almost 6 billion were allocated for reservation bonuses. Last year, applications exceeded the available funds by 1.5 billion
by Dario Aquaro and Cristiano Dell'Oste
Tax credits are somewhat out of fashion, but there is one area where they continue to grow: that of reservation bonuses for investments in special economic zones (Zes) and simplified logistics zones (Zls). In 2024-25, requests for these facilities amounted to 6.7 billion, compared to almost 6 billion in allocations (counting the 133 million added ex post for the agricultural ZES by the last manoeuvre). Resources that could grow by another 532 million, if all the companies that last year asked for the bonus to invest in the single ZES of Southern Italy will be able to obtain the extra credit envisaged by the same Budget 2026 law.
Pros and Cons
Thus, a formula that seemed to have fallen into disuse between 2022 and 2023, after the experience of micro-credits in the Covid period (from sanitisation to electric bikes), is back in vogue. On the contrary, now that the manoeuvre aimed at hyper-amortisation, it can be said that the reservation is the latest way of using an instrument - the tax credit - that has also come under the microscope due to the risk of fraud.
The reservation mechanism provides for the Inland Revenue Agency to determine, a posteriori, the actual percentage of the tax credit, by cross-referencing the applications received and the funds available. From the state's point of view, there is the advantage of establishing the maximum public expenditure upstream, which is all the more appreciated after the 'unlimited' cost season of thesuperbonus. For companies, on the other hand, it is a matter of having to reckon with an incentive that - in principle - can be used in the F24 form more quickly than maxi-deductions; but with an amount that is only made known at a later date and that often turns out to be lower than the theoretical amount provided for by law.
Between plafonds and recalculations
Scrolling through the measures by which the Inland Revenue set the actual value of these bonuses, we can see that in the years 2020-25 in 14 cases out of 31 the credit was recognised in full, because the pre-allocations did not run out of funds. While in another 17 cases, taxpayers had to make do with meagre allowances, despite the fact that the government intervened at times to increase the endowment of some incentives or shift unused resources. This was most recently the case - as mentioned - for the Agricultural Zones: at the end of the year, the Budget manoeuvre added, a posteriori, 133 million to the plafond of 50 million already set aside for investments made from 1 January to 15 November 2025. Thus automatically recalculating at 58.7839% (micro, small and medium-sized enterprises) and 58.6102% (large enterprises) the percentages that the Agency had already calculated and made known on 12 December last (15.2538 and 18.4805 per cent).
For the single ZES, on the other hand, the additional 2025 contribution established by the manoeuvre is still 'possible'. To the companies that submitted the supplementary communication between 18 November and 2 December 2025, the Inland Revenue today recognises 60.3811% of the amount requested: companies will only be able to obtain an additional 14.6189% - bringing the bonus to 75% - if they have not received the Transition 5.0 credit on the same investments. An application must be submitted to the Revenue (within the terms set by a future provision) and the additional contribution can be used from 26 May to 31 December 2026.
