ZES credit reduced to 60%, Zls incentive without cuts

Zes, incentive reduced to 60% of what is due, while for Zls the incentive remains at 100% of what is requested. It is worse for agriculture, good instead for the fishing and aquaculture sector. This emerges from the provisions of 12 December 2025 that the Agenzia delle Entrate published in order to make known the percentages of the tax credit that can be used for investments made in the Zes and Zls areas.

In the Special Economic Zones (SEZs), a particularly high level of applications was confirmed. This dynamic led to the application of an allocation coefficient that reduced the percentage of credit actually due to 60.3811% of the amount requested. In other words, for example, in areas where the requested contribution was 60% for small enterprises, 50% for medium-sized enterprises and 40% for large enterprises, 36.2% (small enterprises), 30.1% (medium-sized enterprises) and 24.15% (large enterprises) were recognised. These percentages are even lower than the old tax credit in force before ZES.

While the high attractiveness of the instrument testifies to the interest of businesses, it also has a penalising effect on the final benefit, due to the insufficient resources compared to the overall volume of applications submitted. It remains to be seen how the mechanisms already envisaged by the 2025 Budget Law will impact in the event of insufficient resources. Basically, in order to ensure that the single tax credit Zes is fully operational, the measure's financial allocation is not rigid, but can be increased over time. In particular, additional resources may be found through the identification of further resources within the programming of European funds, subject to public finance constraints. In this context, the legislation also recognises the possibility of a contribution by the Regions concerned to the implementation of the single SEZ.

The Ministry of Enterprise and Made in Italy and the regions of the Special Economic Zone for Southern Italy will make known by 15 January 2026, through a special communication sent to the Department for Cohesion Policies and the South of the Presidency of the Council of Ministers the possibility of facilitating the same investments using the resources of the European cohesion policy programmes for the 2021-2027 programming period under their ownership, if the conditions are met and in compliance with the territorial, programming and financial procedures and constraints provided for by the said programmes, indicating the amount of financial resources available to finance the measure.

In sharp contrast, for the Simplified Logistic Zones (Zls), the lower pressure on available resources allowed for the full recognition of the tax credit, equal to 100% of the amount requested, without the application of any proportional reduction mechanism. This also includes eligible investments in the eligible areas of Umbria and Marche. This allows companies to maintain the incentive percentage requested when reserving resources. For the higher incentive areas, the confirmed contribution is 35% for small enterprises, 25% for medium-sized enterprises, and 15% for large enterprises.