ZES Unica: a tax credit for your production investment in Italy

Ten regions form the zone; tax eligibility follows the assisted-area map

ZES Unica is Italy’s unified special economic zone. Since 20 November 2025, its administrative perimeter covers Abruzzo, Basilicata, Calabria, Campania, Marche, Molise, Puglia, Sardinia, Sicily and Umbria. Law 171/2025 brought the whole of Marche and Umbria into that perimeter, including the relevant administrative simplification framework and digital one-stop shop.

The tax credit has a separate geographical test. In Abruzzo, Marche and Umbria, the investment must be in an assisted area identified by the regional aid map; being anywhere in one of those regions is insufficient. Even a listed municipality may be only partly eligible. Umbria’s institutional information, for example, identifies only certain sections of Terni. Check the actual production-site address against the applicable area boundaries.

For an international business, identify the eligible Italian business and the production establishment receiving the assets. The location of a parent company’s headquarters does not replace this test. Administrative authorisation and tax relief are also separate procedures: obtaining a permit does not establish entitlement to the credit.

References: Normattiva — Legge 171/2025: Marche e Umbria nella ZES dal 20 novembre 2025 · Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 438–443: ZES 2026–2028 · Regione Marche — Aree assistite, aliquote e chiusura comunicazioni 2026 · Regione Umbria — Scheda investimenti ZES: aree ammesse e intensità

A qualifying investment project goes beyond buying equipment

The project must meet the EU definition of initial investment, such as establishing a new facility, extending capacity, diversifying production or fundamentally changing the production process, subject to the relevant conditions. Routine replacement of a machine does not automatically demonstrate that requirement. Large enterprises in areas assisted under Article 107(3)(c) must also examine the requirement concerning a new economic activity.

Eligible categories include new machinery, plant and equipment assigned to the production establishment, including financial leasing. Specific expenditure on land and the acquisition, construction or extension of business premises can also qualify where the assets are actually used in the activity. Land and buildings together cannot exceed 50% of the eligible investment. The treatment of premises should not be confused with the new-equipment requirement.

• Minimum project cost: €200,000. Meeting that threshold does not establish eligibility on its own.
• The credit is based on costs up to €100 million per project, with separate calculation restrictions for large projects.
• Goods acquired for sale, consumables and purchases failing the relevant conditions are outside the stated scope.
• Transactions must satisfy market-value requirements and restrictions on control or association between buyer and seller.
• Sector exclusions and the business’s financial/legal status must be checked. This guide concerns the ordinary measure, not the separate agricultural, fisheries and aquaculture regime.

References: Regione Marche — Aree assistite, aliquote e chiusura comunicazioni 2026 · Gazzetta Ufficiale — Decreto 17 maggio 2024, articolo 3: investimenti ammissibili · Regione Umbria — Scheda investimenti ZES: aree ammesse e intensità

Separate the theoretical credit from the amount available to use

There is no single ZES percentage for every investor. The maximum intensity depends on the assisted area, enterprise size under EU rules and the investment characteristics. Size classification must consider relationships with other enterprises, so the headcount of a single local subsidiary may give an incomplete result.

For their respective eligible territories, institutional sources from Marche and Umbria describe ordinary intensities of 35% for micro and small enterprises, 25% for medium enterprises and 15% for large enterprises, with specific conditions for the latter. These figures must be checked against the project and must not be applied to other regions. Large investment projects have additional limits and calculation rules.

The credit declared in the supplementary communication is then subject to the percentage published by the Italian Revenue Agency to keep total claims within the annual allocation. The 2026 allocation process follows the supplementary filings, so full coverage of the theoretical amount cannot be promised now. Other support for the same expenditure must also be checked against the relevant aid ceilings and combination rules.

References: Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 438–443: ZES 2026–2028 · Regione Marche — Aree assistite, aliquote e chiusura comunicazioni 2026 · Gazzetta Ufficiale — Decreto 17 maggio 2024, articolo 7: utilizzo, certificazione e vincoli · Regione Umbria — Scheda investimenti ZES: aree ammesse e intensità

The 2026 filing position and what to prepare for 2027

The process requires an initial communication covering completed and planned investment, followed by a supplementary filing confirming the expenditure actually incurred. The Revenue Agency announced the start of electronic submissions on 31 March 2026; Regione Marche confirms closure on 30 May. The supplementary filing is not a substitute for an omitted initial communication.

• Actual investment reported in the 2026 supplementary communication cannot exceed the amount initially communicated.
• An order or advance payment does not by itself prove completion within the eligible period; the correct Italian tax recognition rules matter.
• Funding legislated through 2028 does not create a continuously open filing window or guarantee the final allocation.

References: Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 438–443: ZES 2026–2028 · Regione Marche — Aree assistite, aliquote e chiusura comunicazioni 2026 · Agenzia delle Entrate — Avvio trasmissioni ZES26 del 31 marzo 2026 · Gazzetta Ufficiale — Decreto 17 maggio 2024, articolo 3: investimenti ammissibili

Example: a €500,000 production line

Assume a small enterprise investing in an eligible assisted area of Marche where a 35% intensity applies, with a wholly qualifying €500,000 initial investment in new machinery. Assume a valid initial communication, timely completion, the required supplementary filing and expenditure certification, no other aid reducing the benefit, and compliance with every other relevant condition.

The theoretical credit is €500,000 × 35% = €175,000. The amount available to use then depends on the official 2026 allocation percentage and the required checks. To illustrate the calculation only, an assumed allocation of 80% would produce €140,000. The 80% is a teaching assumption, not an announced or forecast 2026 allocation.

Your cash-flow plan must still explain how suppliers will be paid and when the recognised tax credit can be used. F24 offsetting reduces eligible payments through the Italian tax system; it is not an invoice discount offered by the machinery supplier or an advance cash payment financing the purchase.

References: Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 438–443: ZES 2026–2028 · Regione Marche — Aree assistite, aliquote e chiusura comunicazioni 2026 · Gazzetta Ufficiale — Decreto 17 maggio 2024, articolo 7: utilizzo, certificazione e vincoli

Evidence, auditor certification and obligations after completion

The dossier should connect the investment project, the production site, individual assets and their expenditure. The actual incurrence of eligible costs and reconciliation with accounting records must be supported by the certification required by the measure, issued by the statutory auditor or other eligible audit professional under the rules. Arrange this role before the supplementary filing deadline rather than reconstructing the record in the final days.

Obligations continue after recognition. The rules address assets entering operation, maintaining activity in the ZES for at least five years after investment completion, and recalculation if assets are sold, disposed of or moved during the prescribed periods. Failure to exercise a finance-lease purchase option may also matter. Use of the credit must remain within the authorised amount and follow the required checks, including applicable anti-mafia clearance.

• Exact location, assisted-area verification and evidence of the production establishment’s availability.
• Initial-investment description and comparison with the establishment’s previous capacity or activity.
• Quotes, contracts, orders, invoices, delivery evidence, accounting entries and relevant commissioning records.
• Enterprise-size classification, other incentives and a reconciliation of overlapping costs.
• Communications, receipts, expenditure certification and a register of ongoing obligations.

References: Gazzetta Ufficiale — Legge 199/2025, articolo 1, commi 438–443: ZES 2026–2028 · Gazzetta Ufficiale — Decreto 17 maggio 2024, articolo 3: investimenti ammissibili · Gazzetta Ufficiale — Decreto 17 maggio 2024, articolo 7: utilizzo, certificazione e vincoli

Start with the production site and procurement programme

Studio Dinamico can support the technical definition of the project, examine the investment programme and organise the evidence needed for an incentive assessment. The work connects equipment, production processes, delivery dates and budget, identifying which parts of the programme are coherent and which need further review with tax advisers and the auditor.

If you already filed for 2026, begin by comparing the accepted communication with the investment that will actually be completed. For a new programme, establish the site, industrial objective and timeline before estimating the credit. International investors should also identify the Italian entity and local advisers involved. This gives 2027 planning an explicit set of assumptions while respecting the closure of the initial 2026 filing window.