Tax credit
The tax credit for investments in the Single SEZ is governed by Article 16 of Decree-Law No. 124 of 19 September 2023, converted, with amendments, by Law No. 162 of 13 November 2023 (the “Southern Decree-Law”).
Law No. 199 of 30 December 2025 (the 2026 Budget Law), Article 1, paragraphs 439 et seq., confirmed the funding of the tax credit for the years 2026, 2027 and 2028.
Procedure for accessing the 2026 tax credit
For the year 2026, for the purpose of benefiting from the tax credit, the 2026 Budget Law, Article 1, paragraph 439, provides that “economic operators shall notify the Italian Revenue Agency, between 31 March 2026 and 30 May 2026, of the amount of eligible expenditure incurred from 1 January 2026, as well as that which they expect to incur by 31 December 2026.”
Failure to comply with this requirement results in forfeiture of the incentive. Economic operators who have submitted the above notification “shall send, between 3 January 2027 and 17 January 2027… to the Italian Revenue Agency, a supplementary notification certifying the completion of the investments indicated in the initial notification.”
The supplementary notification, under penalty of rejection, must also specify the amount of tax credit accrued in relation to the investments actually carried out, together with the relevant electronic invoices and the details of the certification required by the Decree of the Minister for European Affairs, the South, Cohesion Policies and the NRRP of 17 May 2024, published in the Official Gazette No. 117 of 21 May 2024. The supplementary notification must indicate an amount of investments actually carried out that does not exceed the amount declared in the notification submitted between 31 March 2026 and 30 May 2026.
By measure No. 3882 of 30 January 2026, the Director of the Italian Revenue Agency approved the notification forms and supplementary notification forms, together with the related instructions, and defined the procedures for electronic submission.
Eligible entities
The implementing decree of 17 May 2024, setting out the operational provisions for granting the tax credit for investments in the Single SEZ, establishes that all enterprises—regardless of their legal form or accounting regime—may access the tax credit, whether already operating within the Single SEZ or newly established therein, with respect to the acquisition of capital goods intended for production facilities located in the assisted areas of the regions Basilicata, Calabria, Campania, Molise, Puglia, Sardinia and Sicily, as well as in the assisted areas of the regions Abruzzo, Marche and Umbria, as identified in the Regional Aid Map 2022–2027.
The tax credit is granted within the overall expenditure limit set out in Article 16, paragraph 6, of Decree-Law No. 124 of 2023.
The incentive does not apply to entities operating in the steel, coal and lignite industries; in the transport sector—excluding warehousing and transport support services—and in related infrastructure; in the production, storage, transmission and distribution of energy and in energy infrastructure; in broadband; nor in the banking, financial and insurance sectors.
Companies that are in liquidation or dissolution, as well as undertakings in difficulty as defined in Article 2, point 18, of Commission Regulation (EU) No. 651 of 17 June 2014, are also excluded from the scope of the incentive.
Eligible investments
Eligible investments are those forming part of an initial investment project as defined in Article 2, points 49, 50 and 51, of Commission Regulation (EU) No. 651/2014, carried out, pursuant to Article 16, paragraph 4, of the Southern Decree-Law, “from 1 January 2026 to 31 December 2028”. These include the purchase—also through finance lease agreements—of new machinery, plant and equipment intended for existing production facilities or for facilities to be established within the Single SEZ, as well as the purchase of land and the acquisition, construction or expansion of buildings instrumental to the investment and actually used for carrying out the activity within the production facility. In the case of instrumental real estate, investments are eligible even where the assets have previously been used by the transferor or by other parties for the conduct of an economic activity.
The incentive does not apply to goods intended for sale, nor to goods processed or assembled for the purpose of producing items for sale, nor to consumables.
The value of land and buildings eligible for the incentive may not exceed 50% of the total value of the subsidised investment.
Acquisitions carried out between entities that are in a relationship of control or affiliation, as defined in Article 2359 of the Italian Civil Code, are also excluded.
The tax credit is calculated on the basis of the share of the total cost of the eligible assets, up to a maximum of 100 million euros for each investment project. For investments made through finance lease agreements, the cost considered is the cost incurred by the lessor for the purchase of the assets, net of maintenance expenses. Investment projects with a value of less than 200,000 euros are not eligible for the incentive.
The tax credit varies according to the region, the size of the enterprise and the scale of the investment.
Specifically, the tax credit is determined according to the following table:
|
Region |
Small Enterprises |
Medium Enterprises |
Large Enterprises |
||
|
|
Investment Projects (1) |
Large Investment Projects (2) |
Investment Projects (1) |
Large Investments Projects (2) |
|
|
Campania |
60% |
40% |
50% |
40% |
40% |
|
Puglia |
60% |
40% |
50% |
40% |
40% |
|
Basilicata |
50% |
30% |
40% |
30% |
30% |
|
Calabria |
60% |
40% |
50% |
40% |
40% |
|
Sicily |
60% |
40% |
50% |
40% |
40% |
|
Sardinia |
50% |
30% |
40% |
30% |
30% |
|
Molise |
50% |
30% |
40% |
30% |
30% |
|
Puglia (3) |
70% |
50% |
60% |
50% |
50% |
|
Sardinia (3) |
60% |
40% |
50% |
40% |
40% |
|
Abruzzo (4) |
35% |
15% |
25% |
15% |
15% |
|
Marche (4) |
35% |
15% |
25% |
15% |
15% |
|
Umbria (4) |
35% |
15% |
25% |
15% |
15% |
-
Projects with eligible costs not exceeding 50 million euros.
-
Projects with eligible costs exceeding 50 million euros (as defined in point 19 (18) of the Guidelines on regional State aid).
-
For the areas identified for support under the Just Transition Fund.
-
Investments carried out in territories located in “non‑predefined c areas” pursuant to Article 107(3)(c) TFEU.
Method of Use
The tax credit may be used exclusively by way of set‑off, pursuant to Article 17 of Legislative Decree No. 241 of 9 July 1997, by submitting the F24 form solely through the electronic services provided by the Italian Revenue Agency, starting from the working day following the publication of the measure issued by the Director of the Italian Revenue Agency and, in any case, not before the issuance of a second receipt—subsequent to the receipt acknowledging the submission of the supplementary notification—confirming that the applicant has been authorised to use the tax credit.
The tax credit must be indicated in the income tax return relating to the tax period in which it is granted, as well as in the income tax returns for subsequent tax periods until its use is fully completed.
The tax credit may be combined with de minimis aid and with other State aid relating to the same eligible costs, provided that such cumulation does not result in exceeding the maximum aid intensity or amount permitted under the applicable EU rules.
If the assets benefiting from the incentive do not enter into operation by the end of the second tax period following their acquisition or completion, the tax credit shall be recalculated by excluding from the eligible investments the cost of the assets that have not entered into operation. If the assets are disposed of, transferred to third parties, assigned to purposes unrelated to the business activity, or allocated to production facilities other than those that gave rise to the incentive within the fifth tax period following the one in which they entered into operation, the tax credit shall be recalculated by excluding the cost of such assets from the eligible investments.
Beneficiary enterprises must maintain their activity within the Single SEZ for at least five years after the completion of the investment, failing which the benefits granted shall be revoked.
For the purpose of recognising the tax credit, the actual incurrence of eligible expenditure must be certified by a statutory auditor or an authorised auditing firm.