Edited by Giovanni Marra, Andrea Brignoli, Annamaria Coppotelli and Alessandro Sinopoli
With the final approval by the Chamber of Deputies at its session of 30 December 2025, following the Senate’s approval on 23 December, the 2026 Budget Law was adopted. The law was promulgated on the same day by the President of the Republic and published in the Official Gazette as Law No. 199 of 30 December 2025, entitled “State budget for the financial year 2026 and multiannual budget for the three-year period 2026–2028”.
The measure includes a complex package of incentive measures in support of the productive system, which underwent numerous amendments and additions during the parliamentary process, significantly affecting the structure originally outlined in the government’s draft bill.
Among the most significant measures introduced by the 2026 Budget Law are, in particular, the strengthening of support instruments for investments in capital goods and for technological and digital innovation processes, the refinancing and reshaping of certain territorial and sectoral tax credits, as well as the introduction of measures specifically targeted at some strategic productive sectors.
Tax incentives
Increased depreciation allowance for investments in capital goods (paragraphs 427-437)
One of the most significant measures of the 2026 Budget Law in the field of tax incentives concerns the introduction of a new increase in the fiscally relevant cost of investments in capital goods (so-called new hyper-depreciation), intended to replace the Transition 4.0 and 5.0 tax credit system.
For business income, taxpayers making investments in capital goods intended for production facilities located within the territory of the State, the acquisition cost of the assets—relevant for the purposes of calculating depreciation quotas and finance lease payments—is increased according to a mechanism of progressive rates based on investment brackets. Specifically, the increase is granted at the following rates:
- 180% for investments up to EUR 2.5 million;
- 100% for investments exceeding EUR 2.5 million and up to EUR 10 million;
- 50% for investments exceeding EUR 10 million and up to EUR 20 million.
The incentive applies to investments carried out from 1 January 2026 to 30 September 2028, provided that the eligible assets are produced in a Member State of the European Union or in a State that is part of the European Economic Area.
The increase is granted for investments relating to:
- new tangible and intangible capital goods included in Annexes IV and V to the Budget Law, provided that they are interconnected with the company’s production management system or supply chain network;
- new tangible assets aimed at the self-production of energy from renewable sources for self-consumption, including remote self-consumption, as well as energy storage systems. With specific reference to solar energy, only installations equipped with high-efficiency photovoltaic modules, as identified by current legislation, are eligible.
From a subjective standpoint, the benefit is excluded for companies in liquidation, subject to insolvency proceedings, or recipients of disqualifying sanctions pursuant to Legislative Decree No. 231/2001. In any case, access to the incentive is conditional upon compliance with workplace health and safety regulations and the proper fulfilment of social security contribution obligations.
Access to the benefit is subject to the electronic submission of specific communications and certifications via an IT platform managed by the Energy Services Operator (GSE), according to procedures to be defined by an implementing decree of the Ministry of Enterprises and Made in Italy, in agreement with the Ministry of Economy and Finance.
The increased depreciation is cumulative with other national and European incentives relating to the same costs, provided that the cumulative amount does not exceed the cost incurred and that the different measures do not apply to the same investment portions.
Investments benefiting from the “Industry 4.0 tangible assets” tax credit provided for by the 2025 Budget Law are expressly excluded from the scope of application.
New funding for the Industry 4.0 tangible assets tax credit (paragraph 770)
Alongside the new hyper-depreciation regime, the 2026 Budget Law provides for the allocation of additional resources in support of the tax credit for investments in Industry 4.0 tangible assets. The Fund to be allocated has a total endowment of EUR 1.3 billion for the year 2026, aimed at strengthening support measures for productive investments.
These resources may be allocated—limited to investments carried out by 31 December 2025—to increase the expenditure caps of the tax credit referred to in Article 1, paragraph 446, of Law No. 207/2024. The tax credit thus granted may be used exclusively by way of set-off, pursuant to Article 17 of Legislative Decree No. 241/1997, through the filing of the F24 tax payment form during the year 2026.
The measure does not introduce a new incentive but rather constitutes a financial reinforcement of an existing scheme, aimed at ensuring budgetary coverage for tax credit claims accrued in relation to investments made during the year 2025.
Industry 4.0 tax credit for the agricultural, fisheries and aquaculture sectors (paragraphs 454–459)
A further significant development is the introduction of a tax credit specifically dedicated to enterprises operating in the agricultural, fisheries and aquaculture sectors, intended to support the process of technological innovation also within primary production activities.
Enterprises active in the above-mentioned sectors that carry out investments in new Industry 4.0 tangible and intangible capital goods, included in Annexes IV and V to the Budget Law, are granted a tax credit equal to 40% of the cost, up to a maximum eligible investment amount of EUR 1 million.
The incentive applies to investments carried out from 1 January 2026 to 28 September 2028, within overall expenditure limits set at EUR 2.1 million for each year of the 2026–2028 three-year period. The tax credit may be used exclusively by way of set-off through the F24 form, starting from the year following that in which the expenditure is incurred, without the application of the general annual limits on tax credit offsetting. For investments carried out through leasing contracts, the relevant cost is the one borne by the lessor.
The measure does not apply to investments benefiting from:
- the new hyper-depreciation regime;
- the Agriculture and Fisheries ZES tax credit;
- the Industry 4.0 tangible assets tax credit provided for by the 2025 Budget Law.
Cumulation with other incentives is instead allowed, subject to the maximum limit represented by the cost incurred. For control purposes, beneficiaries are required to retain appropriate accounting documentation and a certification issued by a statutory auditor, with the possibility of increasing the tax credit—up to a maximum of EUR 5,000—to cover certification costs for enterprises not subject to statutory audit obligations.
ZES and ZLS tax credits (paragraphs 438–452)
A further important development introduced by the 2026 Budget Law concerns the extension of the tax credit for investments in the Single Special Economic Zone (ZES unica) of Southern Italy for the years 2026, 2027 and 2028. The overall expenditure ceilings are set at EUR 2.3 billion for 2026, EUR 1.0 billion for 2027 and EUR 750 million for 2028.
Access to the tax credit continues to be granted to enterprises – regardless of their legal form or accounting regime – already operating or newly established within the Single ZES, which also includes the incentivised areas of the Marche and Umbria Regions, provided that they carry out eligible investments in accordance with the relevant legislation. The exclusion remains in force for entities operating in sectors expressly identified by the incentive framework, as well as for enterprises in voluntary or compulsory liquidation or subject to winding-up proceedings.
Eligible investments must be attributable to an initial investment project involving:
- the acquisition, including through finance lease agreements, of new machinery, plant and equipment intended for existing or newly established production units located within the perimeter of the Single ZES;
- the purchase of land, as well as the construction, acquisition or expansion of buildings having an instrumental nature and functional to the implementation of the eligible investment.
In any case, the total cost attributable to land and buildings may not exceed 50% of the total amount of eligible investment.
Starting from 2026, access to the tax credit is subject to a procedure similar to that already adopted for the 2024 and 2025 incentives, structured in two phases: the submission of an “initial” communication to be filed between 31 March and 30 May of each year, and a “supplementary” communication certifying the investments actually carried out, to be submitted to the Revenue Agency by 17 January of the following year.
For the three-year period 2026–2028, the maximum amount of the tax credit actually usable will be determined by applying a percentage defined annually by the Italian Revenue Agency, calculated as the ratio between the overall expenditure ceiling and the total amount of applications submitted by enterprises. Where applications exceed the available resources, the tax credit due will be proportionally reduced based on the submitted requests.
Finally, the new provisions establish that enterprises which have correctly submitted the supplementary communication to the Italian Revenue Agency for 2025 investments will benefit from an additional tax credit equal to 14.6189% of the amount of the credit already granted pursuant to Revenue Agency measure No. 570046 of 12 December 2025, which had set the percentage of the actually usable tax credit at 60.3811%. As a result, enterprises may benefit from a total tax credit equal to 75% of the amount requested.
It is however provided that the sum of the additional tax credit and the credit already granted may not exceed the amount indicated in the 2025 supplementary communication, and that the additional tax credit is granted on the condition that the enterprises have not obtained, with reference to one or more investments covered by the supplementary communication, the recognition of the Transition 5.0 tax credit.
A similar extension is also provided, pursuant to Article 1, paragraphs 444–447, of Law No. 199/2025, for the tax credit relating to investments in Simplified Logistics Zones (ZLS) referred to in Article 13, paragraph 1, of converted Decree-Law No. 60/2024. In this case, the incentive applies to investments carried out from 1 January 2026 to 31 December 2028, with the access procedure remaining unchanged.
ZES tax credit for agriculture and fisheries (paragraphs 462–466)
The extension for the year 2026 of the tax credit for investments in the agriculture, fisheries and aquaculture sectors within the Single ZES has also been provided. The incentive constitutes a tax support measure in favor of enterprises carrying out investments in capital goods intended for production facilities located in the territories included in the ZES of Southern Italy.
The incentive applies to investments carried out from 1 January 2026 to 15 November 2026 (reference deadline for eligible expenditure). For the purposes of accessing the tax credit for 2026, beneficiaries are required to submit to the Italian Revenue Agency:
- between 31 March and 30 May 2026, a communication indicating the total amount of eligible expenditure;
- between 20 November and 2 December 2026, a supplementary communication certifying the investments actually carried out.
The Budget Law has also provided for an increase in the tax credit rates applicable to investments in the agricultural sector. In particular, the incentive is granted at a rate of 58.7839% for micro, small and medium-sized agricultural and forestry enterprises, and at a rate of 58.6102% for large agricultural enterprises, in accordance with the applicable size classification.
These rates apply automatically, depending on the allocation of available resources, without the need to submit additional applications or communications beyond those required for ordinary access to the tax credit, subject to compliance with the limits and conditions laid down by State aid legislation.
Tax credit for design and aesthetic ideation activities (paragraphs 925–926)
The Budget Law has extended to the year 2026 the availability of the tax credit relating to design and aesthetic ideation activities referred to in paragraph 202 of the 2020 Budget Law. The tax credit amounts to 10% of the relevant tax base, determined net of any other subsidies or contributions, however received, relating to the same eligible expenditure.
The benefit is in any case granted within an annual maximum limit of EUR 2 million, to be proportionally adjusted in the event of a tax period shorter or longer than twelve months, and within an overall national expenditure ceiling of EUR 60 million for the year 2026.
For the purposes of monitoring expenditure ceilings, enterprises are also required to submit electronically to the Ministry of Enterprises and Made in Italy a specific communication indicating the amount of expenditure incurred and the corresponding tax credit accrued.
The tax credit relating to 2026 may be used exclusively by way of set-off through the F24 form, pursuant to Article 17 of Legislative Decree No. 241/1997. Unlike previous years, the credit is no longer spread over three annual instalments but is usable in a single annual instalment, starting from the tax period following that in which it accrues. In any case, utilisation is subject to the fulfilment of accounting certification obligations by the statutory auditor.
Transition 5.0 tax credit for energy-intensive enterprises (paragraphs 962–965)
The recognition of a tax credit for energy-intensive enterprises is provided for, based on the “Transition 5.0” measure set out in Article 38 of Decree-Law No. 19/2024. The incentive is granted to enterprises included, for the year 2025, in the list of electricity-intensive enterprises or in the list of natural gas-intensive enterprises, established with the Energy and Environmental Services Fund (CSEA).
The tax credit is granted in relation to investments carried out between 1 January 2025 and 31 December 2025, relating to new tangible and intangible assets instrumental to the business activity, included in Annexes A and B to Law No. 232 of 11 December 2016 (Industry 4.0 tangible and intangible assets).
As a general rule, the rates provided for under the previous “Transition 5.0” tax credit apply; however, the implementing decree will be required to determine the maximum credit percentages that may be granted, also in light of compliance with the overall expenditure limits.
The overall expenditure ceiling is set at EUR 10 million for the year 2026. The tax credit may be used exclusively by way of set-off through the F24 form, pursuant to Article 17 of Legislative Decree No. 241 of 9 July 1997, and is not cumulative with other incentives relating to the same eligible costs.
In addition to the above, the 2026 Budget Law introduces a structured package of measures aimed at supporting the competitiveness of the national productive system, with particular emphasis on investments in innovation, sustainability and industrial development. These measures are characterised by the strengthening of existing incentive instruments and by the introduction of new support schemes dedicated to strategic sectors, including tourism.
Grants
Refinancing of the “Nuova Sabatini” scheme (paragraph 468)
The 2026 Budget Law provides for the refinancing of the “Nuova Sabatini” scheme, in line with the continuation of measures supporting investment by micro, small and medium-sized enterprises. To this end, appropriations of EUR 200 million for 2026 and EUR 450 million for 2027 are envisaged.
Refinancing of Development Contracts (paragraph 471)
The 2026 Budget Law allocates new funding to support investment projects of strategic importance for the country. In particular, EUR 250 million are allocated for 2027, EUR 50 million for 2028 and a further EUR 250 million for 2029.
Financial incentives for the development of the tourism offer (paragraph 469, replacing paragraph 502 of Article 1 of the 2025 Budget Law)
The 2026 Budget Law introduces a new incentive framework aimed at promoting the transformation of the tourism sector, with particular focus on the deseasonalisation of tourist flows, the digitalisation of the tourism ecosystem, the development of integrated tourism supply chains, and investments compliant with ESG criteria and sustainable tourism. The implementing provisions of this framework will be defined by decree of the Ministry of Tourism, in cooperation with the Ministry of Economy and Finance and the Regions.
Non-repayable grants for the tourism supply chain (paragraph 470)
With regard to the tourism sector, the 2026 Budget Law provides for the allocation of EUR 50 million for each of the financial years 2026, 2027 and 2028, aimed at supporting private investment in the sector. The envisaged contributions may also include non-repayable grants. The criteria and implementing procedures will be defined by ministerial decree within sixty days of the entry into force of the law.
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