Good news for businesses in the Special Economic Zone (ZES) of Southern Italy. The tax credit for the unique ZES of the South has officially been unlocked, with a measure worth 1.8 billion euros. The Minister of Economy, Giancarlo Giorgetti, has signed the implementing decree for the measure, adopted by the Ministry for European Affairs, the South, Cohesion, and the PNRR, in collaboration with the Ministry of Economy and Finance (MEF).
Narrow Timeframe for Communications
Interested businesses will need to notify the Revenue Agency of the eligible expenses incurred from January 1, 2024, and those they intend to incur by November 15, 2024. The period for these communications is set from June 12 to July 12, 2024. A subsequent provision from the Revenue Agency will define the communication model. During this phase, consultants will play a key role, supporting businesses in meeting these requirements and optimizing their investment strategies.
ZES Tax Credit: Scope of Application
The tax credit is available to all businesses, regardless of legal form and accounting regime, that are already operating or are setting up in the unique ZES. Investments must range between 200,000 euros and 100 million euros, as defined by EU Regulation 651/2014.
Types of Eligible Investments
The following are eligible for the tax credit:
- Purchase or leasing of machinery, plants, and equipment for new structures.
- Purchase of land and the acquisition, construction, or expansion of instrumental properties, up to 50% of the total value of the eligible investment.
Excluded are goods intended for resale, those transformed or assembled for final sale, and consumables.
Geographical Area
The geographical area of the unique ZES includes the assisted zones of the regions of Basilicata, Calabria, Campania, Molise, Puglia, Sardinia, Sicily, and certain areas of Abruzzo identified in the Regional Aid Map for 2022-2027.
Regional Differentiation
The tax credit varies depending on the region and the size of the businesses. As indicated by reteagevolazioni.it, the contribution, in the form of a tax credit, at the maximum rate allowed by the Regional Aid Map for 2022-2027, is as follows:
|
Regions |
Small Businesses (up to 50 million investment) |
Medium Businesses (up to 50 million investment) |
Large Businesses (and SMEs over 50 million investment) |
|
Abruzzo (zone assistite) |
35% |
25% |
15% |
|
Molise |
50% |
40% |
30% |
|
Sardegna |
50% |
40% |
30% |
|
Sardegna (area transizione giusta) |
60% |
50% |
40% |
|
Campania |
60% |
50% |
40% |
|
Puglia |
60% |
50% |
40% |
|
Puglia (area transizione giusta) |
70% |
60% |
50% |
|
Basilicata |
50% |
40% |
30% |
|
Calabria |
60% |
50% |
40% |
|
Sicilia |
60% |
50% |
40% |
For investments under 50 million euros, the maximum limits have been increased by 10% for medium-sized businesses and 20% for small businesses. The maximum benefit can reach 70% for a small business investing less than 50 million euros in the province of Taranto or in the Sulcis area.
Controls and Limits
For projects exceeding 50 million euros, the incentive is calculated according to the “corrected aid amount” methodology of EU Regulation 651/2014. A strict control mechanism is in place to ensure compliance with the resource ceiling, set at 1.8 billion euros. If requests exceed this limit, the tax credit will be proportionally reduced among eligible beneficiaries.
Cumulability and Constraints
The ZES tax credit is not cumulative with the Transizione 5.0 program, but it can be combined with incentives that are not state aid, de minimis aid, and other state aids concerning the same costs, provided that the maximum aid intensity allowed by EU rules is not exceeded.
If the machinery subject to the investment does not become operational within the second year, the tax credit will be recalculated downward. The same applies if, within the first five years, the asset is disposed of, sold to third parties, used for purposes unrelated to the business operation, or moved to production facilities different from those that qualified for the benefit. Moreover, businesses are required to maintain their operations in the ZES for at least five years after completing the investment, or they will lose the benefits.
Businesses must submit a prior communication to the Revenue Agency and obtain mandatory certification from an auditor or an authorized company, confirming the actual expenses incurred.