Description
The Transition 5.0 Plan (Decree-Law No. 19/2024, converted with amendments by Law No. 56/2024), aims to provide companies with additional tools to address the dual challenge of digital and green transition, under the new Mission 7 'REPowerEU' envisaged by the PNRR remodelled following the ECOFIN Council decision of 8 December 2023.
The measure grants a tax credit proportional to the expenditure incurred to companies that in the years 2024 and 2025 make new investments in production facilities located in the territory of the State as part of innovation projects resulting in a reduction in energy consumption of no less than 3% per production unit or 5% per process.
With the Budget Law 2025 significant changes were introduced on the thresholds, the tax credit is recognised to the extent of 35 per cent of the cost, for investments up to EUR 10 million, and to the extent of 5 per cent of the cost, for investments over EUR 10 million and up to the maximum limit of eligible costs of EUR 50 million per year per beneficiary company. The tax credit measure is increased according to the certified improvement in energy efficiency. Projects must be certified by an independent evaluator, with ex ante and ex post certification.
Eligible investments are investments in new tangible and intangible assets that are instrumental to the operation of the business set out in Annexes A and B of the Transition 4.0 Plan and which are interconnected to the company's production management system or supply network. Investments in new capital goods aimed at the self-production of renewable energy and, within certain limits, training expenses are also eligible.
The 2025 Budget Law extends the possibility of cumulation of the facilitation, allowing it to be cumulated with the ZES tax credit and removing the restriction of cumulability with only measures based on national resources. The possibility of cumulation with all facilities, including those financed with European funds, was therefore introduced, provided that the support does not cover the same cost shares of the individual investments of the innovation project.
It also introduced the following procedural simplifications
- for the replacement of machinery that has completed its depreciation period by more than 24 months, an exemption from the calculation of the energy savings achieved has been provided for, with the application of the parameters provided for the first bracket of energy consumption reduction, without prejudice to the possibility of demonstrating a higher contribution to energy savings
- for 4.0 assets acquired by means of an EPC (Energy Performance Contract) with an ESCo, automatic recognition of the planned energy efficiency with application of the parameters envisaged for the first energy consumption reduction bracket.
The aforementioned changes also apply to procedures already started at the date of entry into force of the Budget Law 2025.
For further information, please refer to the website of Gestore Servizi Energetici S.p.a. (GSE), which takes care of the implementation of the measure for the Ministry.