Italy’s 2026 hyper-depreciation: machinery, software and energy investment

Establish the Italian beneficiary before assessing the equipment

The measure includes resident businesses and Italian permanent establishments and is not restricted to SMEs. The investment must serve a production facility in Italy. For an international group, identify which entity acquires the asset, bears the expense and calculates taxable business income in Italy. A group connection to Italy does not make every overseas equipment purchase eligible.

Company conditions matter before the asset assessment. The law excludes specified liquidation and insolvency situations and businesses subject to certain disqualifying sanctions; compliance with workplace safety and social security obligations is also required. Separately, the actual financial value depends on the taxpayer’s position and ability to use deductions. Involve the company’s Italian tax adviser when modelling that value.

References: MIMIT — Nuovo Piano Transizione 5.0, Iperammortamento · Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 401–500

Match the technical configuration to the qualifying category

The digital investment route concerns new capital assets listed in Annexes IV and V to Law 199/2025 and interconnected with production management or the supply network. A supplier’s “Industry 4.0” label is not the classification evidence. Software also needs a precise match to the relevant category; ordinary IT expenditure should not be treated as qualifying simply because it supports the business.

The energy route covers new renewable generation assets for self-consumption, including qualifying remote self-consumption and related storage. Electrical generation is limited to a design output of 105% of the facility’s energy requirement calculated under the implementing rules. Technology requirements, photovoltaic module conditions and eligible cost ceilings also apply. An installation quote should therefore be assessed alongside consumption data and the system design.

• Machinery: identify its production function, legal category, installed configuration and data exchange.
• Software: distinguish the qualifying asset from support subscriptions, generic services and unrelated costs.
• Energy: collect consumption records, facility details, connection arrangements and technology specifications.
• Mixed budgets: keep supported, uncertain and excluded cost items visible instead of treating the entire quotation as eligible.

References: MIMIT — Nuovo Piano Transizione 5.0, Iperammortamento · MIMIT — Decreto attuativo 7 maggio 2026 · Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 401–500

Calculate the extra deduction before calculating the tax saving

The percentages increase the deductible cost; they are not percentages of the invoice refunded by the government. The implementing decree applies the bands to eligible investment completed in each year. An investment spanning more than one band needs a marginal calculation. To produce a useful business case, establish eligible cost after other support, the applicable tax rate and the timing of the deductions.

References: MIMIT — Decreto attuativo 7 maggio 2026

Worked example: €100,000 of qualifying equipment

Assume €100,000 of eligible cost, no other subsidy on those costs, the entire investment within the first band and all eligibility conditions satisfied. The extra deduction is €100,000 × 180% = €180,000. Including the ordinary asset cost, the theoretical total deductible base is €280,000, used under the applicable tax depreciation or leasing rules.

For illustration, assume a constant 24% income tax rate and full use of the deductions. The additional nominal tax saving would be €43,200. It would not be cash available on the purchase date. This calculation excludes discounting, tax changes, financing and documentation costs; annual amounts depend on the taxpayer’s situation. A positive GSE completion outcome and the relevant entry-into-service condition remain necessary before the benefit can be used.

References: MIMIT — Decreto attuativo 7 maggio 2026

Follow the GSE sequence and distinguish the stages already open

The initial communication identifies the company, facility, assets, costs and expected implementation dates. This stage opened on 12 June 2026. Following a positive outcome, the business has 60 days to submit confirmation documenting a deposit of at least 20% for each asset; that function opened on 21 July. Finance leases follow the decree’s specific rule based on the lease agreement and the lessor’s purchase commitment.

Completion follows implementation and, for digital assets, interconnection. Its general submission deadline is 15 November 2028. However, the 20 July decree explicitly reserves the opening of that function to a later measure. The sources reviewed on 9 September did not confirm that opening. A statutory deadline is not evidence that the submission function is operational: check the latest MIMIT notices and GSE forms before relying on an intended filing date.

References: MIMIT — Nuovo Piano Transizione 5.0, Iperammortamento · MIMIT — Decreto attuativo 7 maggio 2026 · MIMIT — Decreto 20 luglio 2026, conferma degli investimenti · GSE — Nuovo Piano Transizione 5.0, documenti e modelli

Build the tax milestones into the production schedule

The 30 September 2028 deadline concerns completion as defined by the implementing decree. An accepted order, physical delivery, entry into service and interconnection can occur on different dates. An order placed within the investment window does not, by itself, extend the completion deadline. Asset substitutions and higher costs between communications also need to be assessed against procedural restrictions.

The uplift starts in the tax period when the completion communication is submitted, provided the asset enters service within that period, and remains conditional on GSE’s positive outcome. Annual monitoring communications are also provided for, on 20 January and 30 June. Assign a technical owner and an administrative owner so that installing the equipment does not become disconnected from the evidence and reporting programme.

References: MIMIT — Decreto attuativo 7 maggio 2026

Prepare technical and accounting evidence as the project develops

The decree requires a sworn technical report with supporting analysis, or the specified attestation from an accredited body, to demonstrate qualifying characteristics and interconnection or energy conditions. It also requires accounting certification of the expenditure. Do not assume that a documentary simplification remembered from an earlier tax incentive applies to the new 2026 measure.

A usable evidence file connects the final quotation, order, invoice, payment and delivery record to identifiable assets. Add system diagrams and interconnection evidence, or consumption data and the energy installation design. Reconcile communicated figures with the accounting records. Agree the supplier’s technical deliverables before procurement and identify the appropriately qualified professionals needed for certification; the supporting file does not replace their work.

References: MIMIT — Decreto attuativo 7 maggio 2026

Combining incentives requires an asset-by-asset calculation

The law permits other support subject to restrictions: no duplicate coverage of the same cost portions, no funding beyond the cost incurred, and an eligible calculation base reduced by other subsidies or contributions received for those costs. The uplift cannot apply to investments benefiting from the specific Industry 4.0 credit referenced in Article 1(446) of Law 207/2024.

If Nuova Sabatini is also being considered, avoid adding headline percentages to the full purchase price. Create a schedule showing each asset, its cost, each support instrument, the covered amount and the remaining tax calculation base. The rules of both measures matter, including any specific incompatibility affecting an energy project. Review the resulting financial model with the Italian tax adviser before approving the investment budget.

References: Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 401–500

Turn the investment idea into a decision the business can assess

Studio Dinamico can support the technical definition of the investment and the assessment of relevant incentives: connect assets to production objectives, clarify automation and software scope, identify missing supplier evidence and align implementation with the administrative timetable. The assessment starts with the project’s characteristics and open questions rather than a promised award.

For equipment already selected, the useful first output is a requirements list with the evidence still needed from the supplier. For an investment at concept stage, it is a comparison of technical options and cost boundaries that management and the administrative team can discuss. Technical reports and accounting certifications require the qualified parties specified by the measure; their responsibilities and appointments must be established within the project.