Edited by Vitalba Passarelli, Giovanni Marra and Brisilda Bibaj
The 2025 budget law (art. 1 paragraphs 485-491 of Law 207/2024) has extended to 2025 the tax credit for investments in the single SEZ of Southern Italy pursuant to art. 16 of Legislative Decree 124/2023, originally planned for 2024 only.
This provision represents an important initiative aimed at stimulating the economic development of companies operating in the regions of Southern Italy, specifically in the regions of Basilicata, Calabria, Campania, Molise, Puglia, Sardinia, Sicily and Abruzzo, the latter limited to the assisted areas and the types of investment as identified by the 2022-2027 Regional Aids Charter.
Main innovations introduced by the 2025 budget law
The overall spending limit allocated for the 2025 financial year, equal to 2.2 billion euros, concerns investments made in the period between 1 January and 15 November 2025.
The access procedure is substantially in line with the forecasts of the previous financial year, modifying only the timing of the ordinary and supplementary communications.
An important change concerns the possibility of cumulating the single SEZ tax credit with the Transition 5.0 tax credit, initially excluded for 2024 investments, which makes this benefit even more attractive for businesses.
Eligible investments
In continuity with the provisions of the previous legislation, the following investments are eligible:
- the purchase, including through financial leasing contracts, of new machinery, systems and various equipment functional to: i) the creation of a new plant; ii) the expansion of the production capacity of an existing plant; iii) the diversification of the production of a plant to obtain products never previously manufactured; iv) the fundamental change in the overall production process of an existing plant;
- the purchase of land and the acquisition, construction or expansion of properties instrumental to the investments. The value of the land and properties cannot exceed 50% of the overall value of the eligible investment.
Likewise, the maximum spending limit for each investment project, equal to 100 million euros, remains unchanged, as does the exclusion of investments whose value is less than 200 thousand euros.
Maximum intensity of the relief and how to use it
The amount of the theoretical tax credit is differentiated by region, company size and amount of investments and it can reach, for SMEs, the maximum rate of 60% in the case of investments up to 50 million euro and 40% in the case of investments exceeding 50 million euro.
The tax credit, moreover:
- can be used exclusively in F24 form offsetting via the Revenue Agency’s telematic channels, following a positive outcome of the Agency’s anti-mafia checks and first-level checks (while substantial checks can take place following the use of the credit);
- must be indicated in the tax return relating to the tax period in which the credit accrues and in the tax returns relating to subsequent tax periods up to the one in which its use ends.
Access procedure for the incentive
As anticipated, to obtain the SEZ tax credit, an access procedure similar to that of the 2024 incentive is foreseen, but with different timing. For the year 2025, companies interested in the incentive must:
- communicate to the Revenue Agency, from 31.3.2025 to 30.5.2025, the amount of eligible expenses that they expect to incur by 15.11.2025;
- send to the Revenue Agency, under penalty of forfeiture of the incentive, from 18.11.2025 to 2.12.2025, an additional communication, certifying that the investments indicated in the original communication submitted have been made by the deadline of 15 November.
With provision no. 25972/2025 the Revenue Agency approved the communication models for the use of the SEZ tax credit, with the related instructions, also admitting the following to the benefit:
- investments lasting several years, started in 2024 and concluded after 31 December 2024;
- accounts paid and invoiced before 1 January 2025 (but not before 19 September 2023) for investments made from 1 January to 15 November 2025.
The instructions for completing the SEZ communication require the use of the ATECO 2025 codes, mandatory starting from 1 April 2025. In fact, the lack of correspondence between the code resulting in the tax register and the code present in the communication will be sufficient to access the benefit to determine the discard of the communication itself.
The verification can be carried out directly, or through an intermediary delegated to the tax drawer, by accessing the personal area of the Revenue Agency website: tax drawer, Consultation / Personal data / Activity carried out area (for the main activity) and Other activities (for secondary activities).
The maximum amount of the tax credit that can be used will be equal to the amount of the tax credit resulting from the supplementary communication multiplied by the percentage disclosed by the Revenue Agency provision (to be issued within ten days of the deadline for submitting the supplementary communications), obtained by comparing the spending limit to the total amount of the tax credits indicated in the supplementary communications.
It is worth noting that, during the 2024 edition, companies obtained 100% of the amount of the credit requested with the supplementary communication.
Certification of expenses and methods of use
For the purposes of recognizing the tax credit, the actual incurrence of eligible expenses and their correspondence to the accounting documentation prepared by the company must result by a specific certification issued by the person/company in charge of the legal audit of accounts. For companies not required by law to have the legal audit of accounts, the certification is issued by a legal auditor or by a legal auditing company, registered in section A of the register referred to in art. 8 of Legislative Decree 27 January 2010, no. 39.
Cumulation with other benefits
The tax credit may be cumulated with de minimis aids and State aids, provided that such cumulation does not lead to exceeding the intensity or the highest amount of aid envisaged by the relevant European regulations. Furthermore, the tax credit can be cumulated, within the limits of the expenses actually incurred, with other incentive measures that are not classifiable as State aids pursuant to art. 107 of the TFEU.
As anticipated, the changes introduced by par. 427 of the 2025 Budget Law allowed the Transition 5.0 credit to be cumulated with the SEZ tax credit. The primary legislation, however, does not expressly regulate the correct methods of cumulation between the two incentives, making it desirable to have an official clarification on this point that allows companies to access the incentives in conditions of greater operational certainty.
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