Extension and remodeling of the Transition 4.0 plan: glass half empty or half full?


The budget law for 2021 will include the extension of a large part of the Transition Plan 4.0. An undue and unexpected renewal, because the current plan still had one year or more of residual life, and certainly important because it extends the duration until June 2026 for capital goods, until 2031 for research and development and until 2025 for those of innovation and design.


What's missing

Let's say immediately what is not there: there is no extension of the tax credit for non-4.0 assets, be they tangible or intangible, and there is no one for the so-called 4.0 training. But the reasons are profoundly different.


Capital goods not 4.0

As far as capital goods are concerned, the reason is purely economic: it is an incentive which, although revised downwards (for 2022 the rate is 6%), is horizontal and extremely expensive. Suffice it to say that the financing of the 2021 and 2022 annuities (however deliveries will arrive until mid-2023) cost over 8 billion euros, all borne by the Italian tax system because it is a measure that was not part of the PNRR.


On the front of ordinary capital goods, however, we can take home the commitment that the Government has made to revise the depreciation coefficients, up to 1988. And - allow me a judgment on the merits - if it comes to a substantial reduction of the fiscal life of capital goods (even only those with numerical control) the benefit for the company would be much more interesting than a tax credit which, to be compatible with the finances of the state, would have had to be reduced to an unattractive 3% or 4%.


Training 4.0

The speech relating to the tax credit for training 4.0 is completely different. Here the problem was not so much the cost of the measure, for which 150 million euros were allocated each year, which, probably, have never been spent except to a small extent. The point is that it is a facility whose fortunes have been undermined by an unfavorable cost-benefit ratio: too many bureaucratic burdens in the face of scarce tax benefits.


The 2020 edition of the measure, which is currently in force and which will be usable for the whole of next year, has made enormous strides to improve the attractiveness of the incentive, adding to the subsidized expenses also the expenses for trainers and ancillary charges.


Unfortunately, since 2023 this instrument has received an abrupt stop. But there remains present - indeed pressing - the need to which that measure was called upon to respond: that is, to promote the formation of those skills without which enabling technologies cannot express their potential. At the moment all that remains is to advise companies to exploit the incentive as long as it is available, perhaps associating it with inter-professional funds, and to evaluate other interesting incentives which, in some cases, can be extremely convenient. Just think, for example, of the New Skills Fund managed by Anpal, which allows companies to reduce the working hours of employees and start them at the frequency of skills development courses, without decreasing their salary and without costs for the company. .

Hyper-depreciation and simplification

Also missing - but this is not necessarily bad news - is the return to the old regime of the increase in depreciation (the old hyper and super), which the Deputy Minister of Economic Development Gilberto Pichetto Fratin had sponsored, at least as an alternative to the current credit system. tax.


On the other hand, no reorganization and simplification of the measures has been envisaged, not even for the future, starting from those Annexes A and B which still substantially contain the same product categories envisaged in the original plan, while the interpretative guidelines and various FAQs have progressively expanded the application areas (think - to give just one example - of the inclusion of Healthcare in the circular of 1 March 2019 n.48160 ). The entrepreneur who approaches the incentive legislation to assess its compliance with his purchase, not finding clearly the product category of the asset in the list of attachments, in the absence of certainty could be led to renounce the incentive.


Lastly, the discipline of the tax credit for Research, Development, Innovation and Design has not been touched, except in the rates, as we will see shortly. As we know, an amnesty was introduced in the tax decree for all those who benefited from the incentive in the years 2015-2018. This amnesty, however, has moved on the effects, but not on the causes of those objective conditions of uncertainty in which companies have moved.

What's up

Let's get back to what's there now. A brief outline of what the extension provides is needed before moving on to the comment.

Tax credit for tangible capital goods 4.0

2021

50% for investments up to 2.5 million

30% for investments from 2.5 to 10 million

10% for investments from 10 to 20 million

2022

40% for investments up to 2.5 million

20% for investments from 2.5 to 10 million

10% for investments from 10 to 20 million

2023-2025

20% for investments up to 2.5 million

10% for investments from 2.5 to 10 million

5% for investments from 10 to 20 million

Tax credit for intangible capital goods 4.0

2021 - 20%

2022 - 20%

2023 - 20%

2024 - 15%

2025 - 10%

Tax credit for Research, Development, Innovation and Design

2022

20% for research and development activities with a ceiling of 4 million

10% for innovation activities or for design and aesthetic conception activities with a ceiling of 2 million

15% for innovation activities aimed at an ecological transition objective or digital innovation 4.0 with a ceiling of 2 million

2023-2025

10 % for research and development activities with a ceiling of 5 million

5% for innovation activities or for design and aesthetic conception activities with a ceiling of 2 million

10% for innovation activities aimed at an ecological transition objective or digital innovation 4.0 with a ceiling of 4 million

2026-2031

10% for research and development activities with a ceiling of 5 million


Glass half full or half empty?

Now that we have seen what is there, let's take a closer look at the scope of the intervention.

Meanwhile, as we said at the beginning, it is an intervention that was not due. It would have been possible to wait for the next budget law for renewal, as has been done since 2017. The Government, on the other hand, considered it correct to give a signal of stability to companies, anticipating an extension that actually extends for 5 years from today. and in fact represents almost a structuralization of the measures.


Of course - it must be said - there is a significant cut in the rates, almost always halved starting from 2023. However, we remind you that these incentives were created to boost the demand for innovation 4.0, as a "shock cure" which therefore had to last for a short time. time.


Although the treatment has certainly worked, the "patient" is not yet able to resume walking only on his legs. Not only that: the availability of this kind of incentives is also becoming a factor of competition between countries, as the manager of the Ministry of Economic Development Marco CalabrĂ² noted at the meeting organized by Warrant Hub at Dallara in Varano de 'Meregari. . Italy started first, but today the competition, especially from cousins ​​from beyond the Alps, in trying to attract new, important industrial settlements of the multinationals is very tight.


Having therefore clarified the need for an extension, it should also be remembered that the "Santa Claus" hidden under the PNRR banner has passed and will never come back. We must therefore resign ourselves to deal with the landlord who, despite the increase in GDP "well over 6%" (these are the exact words pronounced on the occasion of the presentation of the budget bill by the Prime Minister Mario Draghi) , it cannot work miracles. And so it is necessary to collect a reshaping of the rates which reflects, in fact, the choice of an "exit strategy".


Thinking for example of tangible capital goods 4.0, if in January 2022 there will be a "step" with the passage from 50% to 40% for the investment range up to 2.5 million euros, in January 2023 there will be a "staircase" 40% to 20%.


But it is precisely here that it is worth remembering once again that the new system of depreciation coefficients should be fully operational by that date; and that this 20% is guaranteed as of now for a further three years. If they had told us in January 2017 that we would have arrived at least in June 2026 with these incentives, 

Would we not have signed up?

The situation is different for the tax credit for research, development, innovation and design. Meanwhile, we must collect a differentiated renewal for the measures, with a "preference" given to R&D activities, incentivized until 2031, compared to those of innovation and design supported only until 2025. And then there is the issue of the rates. While for capital goods at least the first bracket of 20% still represents a very respectable rate (just think that for non-4.0 goods the 2021 rate was 10% and the 2022 rate is 6%), here we are facing to the halving of rates that some already criticized as being unattractive. We do not feel like giving a firm judgment on this. The fact is that businesses will certainly have the incentive to… look around for alternatives. One of these is the new Patent Box. Critically criticized - and rightly so - in several respects, the new discipline however guarantees a benefit of more than 25% for those who have trademarks and patents to which to refer the research and development activities.


I would close these considerations with a final note. What we have seen is the first draft of a budget law that will have to pass for almost two months between committees and parliamentary halls. Many say they are convinced that rates and conditions will be revised upwards. Personally, I am not so convinced because it is a question of moving within rather narrow limits that are the financial resources available. Rather, it should be emphasized that improvements are possible in the next budget law, should the economic recovery continue, offering the Government additional resources to manage.