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Guide to the ZES 2024 tax credit

The ZES 2024 tax credit is an important advantage for companies that invest in the Italian South. This incentive, established by the Southern Decree and funded by the 2024 Budget Law for the three-year period 2024-2026, is intended for companies that acquire capital goods for production structures in the regions of Southern Italy, namely Campania, Puglia, Basilicata, Calabria, Sicily, Sardinia, Molise
and Abruzzo.

What is the ZES tax credit

The ZES tax credit is a tax credit that can be offset against tax debts, intended for companies that acquire capital goods for production structures in the special economic zones (ZES) of the South. The facility was established by the Southern Decree and amended by the 2024 Budget Law, which set an annual ceiling of 1,800 million euros. This incentive is subject to the economic limitations of European legislation on state aid.

Implementing Decree

The ZES Sud tax credit is governed by the Ministerial Decree of 17 May 2024, published in the Official Gazette No. 117 of 21 May 2024. Furthermore, Order No. 262747 of 11 June 2024 of the Revenue Agency opened applications on 12 June 2024. These acts also specify the requirements for access to the bonus.

Requirements

The ZES tax credit is due to companies that purchase capital goods for production structures in the regions of Campania, Puglia, Basilicata, Calabria, Sicily, Sardinia, Molise and Abruzzo. Companies in all sectors can access it, except those operating in the steel industry, coal, transport and related infrastructure, energy production and distribution, broadband, as well as in the credit, financial and insurance sectors. Companies in a state of liquidation or in difficulty are also excluded.

How to get a tax credit

To obtain the contribution in the form of a tax credit, interested companies must communicate to the Revenue Agency, from 12 June to 12 July 2024, the amount of eligible expenses incurred from 1 January 2024 and those they expect to incur until 15 November 2024. Within 10 days from the deadline for submitting the communications, the measure that identifies the percentage of concession due will be issued. Starting the next day, you can use the tax credit for investments already made.

ZES 2024 tax credit application

The Revenue Agency has made available an application template with related compilation instructions, downloadable from the Agency’s website. The communication can only be sent electronically through the “ZES UNICA” software available from 12 June 2024. Interested companies must send communications relating to new investments made starting from January 1 and until November 15, 2024.

ZES tax credit percentage

The ZES tax credit is determined to the maximum extent for large companies allowed by the Regional Aid Charter for 2021-2027. In particular:

  • 40% of the costs incurred in relation to eligible investments in the Calabria, Campania, Puglia and Sicily regions.
  • 30% of the costs incurred in the Basilicata, Molise and Sardinia regions.
  • 15% of the costs incurred in assisted areas of the Abruzzo region.

For investment projects with eligible costs not exceeding 50 million euros, the ceilings were increased by 10 percentage points for medium-sized enterprises and by 20 percentage points for small businesses.

How does the ZES tax credit work

The tax credit for the South is a credit against the State that can be used to offset the taxes due. The Ministerial Decree of 17 May 2024 establishes the details of the operation, subject to approval by the European Commission. The credit can be used in compensation and is awarded in compliance with the guidelines established in the Regional Aid Charter for 2021-2027
.

What is included in the tax credit

Investments in new machinery, plants and equipment intended for production structures that already exist or to be created on the territory, the purchase of land, and the acquisition, construction or expansion of capital buildings can be financed with the ZES tax credit. The value of land and buildings cannot exceed 50% of the total value of the subsidized investment. Investment projects whose total cost is less than 200,000 euros are not eligible
.

Advantages of the ZES zone

The Special Economic Zone (ZES) is a delimited area of the State’s territory where economic activities can benefit from special conditions in relation to investments and business development activities. Under the Single Southern SEZ, companies can take advantage of tax breaks and administrative simplifications, such as access to a single authorization to start
activities.

Expiry of the ZES tax credit

The communication to the Revenue Agency for access to the ZES tax credit must be submitted from 12 June 2024 to 12 July 2024.

Cases of revocation of the ZES Sud tax credit

To obtain the benefit, the beneficiary companies must maintain their business in the areas where the investment was made for at least 5 years after the completion of the investment. Otherwise, the benefits will be revoked and the tax credit must be returned
.

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