New Hyper-Depreciation 2026-2028
Art. 1 paragraphs 427-436 of the 2026 Budget Law introduced a new increase in the acquisition cost of capital goods, restoring the Hyper-Depreciation (Iperammortamento) mechanism to replace previous 4.0 and Transition 5.0 tax credits.
The incentive consists of an extra-accounting downward adjustment in the REDDITI tax return, based on investments made from January 1, 2026, to September 30, 2028, equal to:
- 180% for investments up to 2.5 million euros
- 100% for investments from 2.5 to 10 million
- 50% for investments from 10 to 20 million
Key Points:
- Mechanism: Increase in depreciable tax cost.
- Assets: 4.0 Tangible and Intangible Goods + Energy Self-production.
- Cumulability: Possible with other national/EU incentives, net of contributions received.
Beneficiaries and Exclusions
Access to the benefit is reserved exclusively for business income earners resident in the State territory, including permanent establishments of non-resident entities.
Who can access:
- Capital companies (SpA, Srl, Sapa).
- Partnerships (Snc, Sas) and individual commercial enterprises.
- Public and private entities carrying out commercial activities.
- Cooperative societies.
Excluded Subjects:
Professionals (arts and professions), taxpayers in the flat-rate (forfettario) regime, companies in crisis, or those subject to disqualifying sanctions (Legislative Decree 231/2001) are excluded.
Eligible Investment Details
The incentive is conditional on the assets being capital goods for the exercise of the business, new, produced in the EU or EEA, and destined for production facilities located in the State territory.
1. 4.0 Tangible Assets (Annex IV)
Functional assets for technological and digital transformation grouped into four categories:
- Capital Goods: Machines controlled by computerized systems and/or managed via sensors.
- Sustainability and Quality: Systems for quality assurance and environmental sustainability.
- Human-Machine Interaction: Devices for improving ergonomics and workplace safety in 4.0 logic.
- Data Infrastructure: Systems for processing, storing, and transmitting data.
2. 4.0 Intangible Assets (Annex V)
Software, systems, platforms, and applications functional to the digital management of the enterprise, including:
- Algorithms and digital models for monitoring consumption.
- Interconnection platforms for company information systems.
3. Renewable Energy Self-production
Investments in new tangible assets aimed at self-producing energy from renewable sources for self-consumption (including remote), including storage systems.
PHOTOVOLTAIC REQUIREMENTS (DL 181/2023):
- - Modules with cells produced in the EU.
- - Cell-level efficiency ≥ 23.5%.
- - For bifacial heterojunction cells: efficiency ≥ 24%.
Investment Development and Tax Savings
Depreciation and Hyper-Increase Plan (amounts in €)
| Year | Accounting Depr./Lease | Hyper Increase | Ord. Tax Savings | Hyper Tax Savings | Total Tax Savings |
|---|
Increase Detail by Bracket
Percentage of acquisition cost recovered through total tax savings (Ordinary + Hyper).
Total downward adjustment x Tax Rate
Acquisition cost minus total tax savings
Access Procedure and GSE Obligations
The 2026 Hyper-depreciation introduces a paradigm shift: the benefit is no longer automatically accessible but is subject to a rigorous electronic procedure managed by the GSE (Energy Services Manager).
1. Communication System
Companies must transmit three distinct types of documents via the specific platform:
- Preliminary Communication: To be sent before starting the investment, indicating the planned amount and project type.
- Confirmation Communication: Sent during the progress of work to confirm the validity of the original plan.
- Final Communication and Certification: To be transmitted once the investment is completed, containing definitive data and proof of interconnection.
2. Technical Interconnection Requirements
For 4.0 tangible and intangible assets, the incentive is granted only if the asset is interconnected to the company system. This requirement is met if:
- Information Exchange: The asset must send/receive data with the management system (ERP), planning system (MES), or supply network.
- Standard Infrastructure: The connection must be based on open and recognized protocols (e.g., TCP-IP, HTTP, MQTT).
- Unique Addressing: The asset must be uniquely identified on the network, typically via an IP address.
3. Documentary Burdens and Thresholds
Proof of investment varies based on the value of the individual asset:
| Asset Value | Required Documentation |
|---|---|
| Under € 500,000 | Self-declaration by the legal representative pursuant to DPR 445/2000. |
| Over € 500,000 | Sworn technical report (Engineer/Expert) or Certificate of Conformity. |
Accounting and Tax Treatment
Hyper-depreciation operates exclusively for tax purposes as a **downward adjustment** of taxable income. it has no impact on civil law financial statement values.
| Aspect | Treatment |
|---|---|
| Balance Sheet Recognition | At actual acquisition cost |
| Civil Depreciation | Calculated on ordinary rates |
| Tax Adjustment | Extra-accounting downward adjustment |
| Deferred Taxation | Not applicable (permanent adjustment) |