The Milleproroghe Decree does not grant a further extension, as initially rumored, to complete the investments booked by the end of 2022, allowing companies to take advantage of enhanced tax credits. Article 9 of the Milleproroghe Decree confirms the deadline of November 30, 2023, for the realization of investments in tangible assets with Industry 4.0 requirements (see previous article). These investments must have been ordered by December 31, 2022, with a 20% down payment, guaranteeing a 40% credit up to 2.5 million euros.
The deadline also applies to the purchase of tangible and intangible instrumental assets, other than those 4.0, booked by the end of 2022, in order to obtain a 6% tax credit. Law 178/2020, paragraph 1057, provides enhanced tax credits for investments in tangible assets with 4.0 characteristics made in 2022, provided there is a “reservation” with an accepted order and down payment by December 31, 2022. For tax credits related to non-4.0 instrumental goods, refer to the article at this link.
“Halved Regime” for Implementation Challenges.
Companies unable to meet the 2022 timeframe due to difficulties in obtaining raw materials or other reasons will benefit from the provisions of paragraph 1057-bis, with halved credit percentages (20%-10%-5%).
No Changes for Intangible Investments.
The Decree also reinstates the deadline of November 30, 2023, to complete investments in “ordinary” tangible and intangible instrumental assets, booked by December 31, 2022 (paragraph 1055 of Law 197/2020). Failure to comply with this deadline would have resulted in the loss of the incentive, as these types of assets are no longer favored from the current year. The incentive consists of a 6% tax credit up to 2 million in costs for tangible assets and up to 1 million for intangible assets.
The dates for investments in intangible 4.0 assets remain unchanged (Annex B, Law 232/2016). Paragraph 1058 of Law 197/2020 provides a timeframe from November 16, 2020, to December 31, 2023, to avail the 20% tax credit. Beyond this window, paragraph 1058-bis (investments in 2024) will apply with a reduced credit of 10%.
For access to tax credits for Industry 5.0 investments, conditions remain unchanged (see the previous article at the following link).
For further information, consult your tax advisor.
