Simest, extension to 31 May 2022 opening of the 394 Fund / PNRR

In the Official Gazette No. 286 of 1 December, the resolution of the Concessions Committee for the administration of the Fund 295/73 and the fund 394/81 was published, which established that the deadline for the presentation of applications for subsidized loans to benefit from the "Loans Section" and related non-repayable co-financing from the "Contributions Section" of the Fund 394/81 initially set by 6 pm on 3 December 2021, it is extended to 31 May 2022, except for any closure due to exhaustion of resources .

Close to the closing of the portal to access the Fund 394, the extension was therefore approved which will allow companies to take advantage of a further six months to submit their application for access to the Fund.

As reported on the Simest website, there is still ample availability of resources: SMEs still have 360 ​​million euros available of the one billion and 200 million that the Recovery Plan had allocated to the Fund for the internationalization of companies. As of December 1, 2021, 5,860 companies have submitted an application for internationalization , for a total of allocated resources of 840 million euros

The measures, within the PNRR, for which it is possible to apply until May 30, 2022 are:

  • Digital and ecological transition of SMEs with an international vocation
  • Participation of SMEs in international fairs and exhibitions, also in Italy, and system missions
  • Development of electronic commerce of SMEs in foreign countries (e-commerce).

The extension envisaged by the Simest Concessions Committee is also linked to the extension of the terms for the  Temporary Framework , the aid scheme for companies which, in turn, was extended until the end of June 2022 .

However, these two extensions are not the only news regarding Simest. According to an article in Il Sole 24 Ore last November 25th, in a conference organized by Confindustria Syracuse it emerged that: "the Simest tenders for companies that will come out in 2022 will return to finance seven types of interventions".

The seven Simest lines for which companies can apply are:

  • capitalization : for the improvement or maintenance of predetermined levels of capital solidity in order to strengthen exporting companies;
  • participation in international fairs, exhibitions and system missions : to promote the participation of companies and their business in international events; 
  • entering foreign markets : to facilitate the opening of permanent commercial structures abroad;
  • Temporary Export manager : to support the temporary hiring of specialized professional figures in the company;
  • E-Commerce : for the development of e-commerce solutions through the use of a market place or IT platforms developed in-house;
  • Feasibility Studies : for studies related to both commercial and production investments;
  • Technical assistance programs : for staff training in investment initiatives.

In 2022 there will therefore be a return to the previous operating methods, once the PNRR funds have ended, thanks to the resources allocated by Article 12 of the 2022 Budget Bill, which extended the subsidized rate loans and the contribution to 2026 . non -repayable of SIMEST calls.

Specifically, the new provisions, inserted in art. 11 state that "To support the internationalization of Italian companies, the following interventions are arranged:

  • the endowment of the revolving fund ( Fund 394/1981 ) referred to in article 2, first paragraph, of the decree-law of 28 May 1981, n. 251, converted, with modifications, by law 29 July 1981, n. 394, increased 1.5 billion for each of the years from 2022 to 2026 ;
  • the endowment of the  fund referred to in article 72, paragraph 1, of the decree-law of 17 March 2020, n. 18 , converted, with amendments by law 24 April 2020, n. 27, is increased by  150 million euros per year for each of the years from 2022 to 2026 , for the purposes referred to in letter d) of the same paragraph ".

Incentives for business investments in Maneuver 2022

These are decisive weeks for the Italian economic system: the 2022 maneuver is taking shape and concreteness. In particular, after the approval of a first draft by the Council of Ministers on 28 October last, an intense revision of the text of the 2022 Budget was carried out. A new draft of the 2022 Budget Law has emerged in the last few years. days, despite the considerable delay with respect to the deadline of 20 October by which the document should have been sent to the Chambers.

While waiting for the parliamentary process to be completed, it is immediately striking how the 2022 Budget Law certainly bears the significant advantage of finally abandoning the mechanism of precarious annual renewals of incentive disciplines, on which a structured investment planning certainly cannot bear.

In the context of the technical report of the Maneuver that arrived in the Senate, the financial effects of the extensive extensions contained therein also emerge. In particular, over € 14.149 billion of resources are allocated for the multi-year extension of the Transition Plan 4.0 . More specifically, € 6.827 billion is envisaged for the tax credit for investments in capital goods 4.0 for the three-year period 2023-2025 and a total of € 7.276 billion for the R&D Innovation Design tax credit up to 2023-2025 / 2031. To grasp its extent, just think that between the PNRR and the complementary fund in force today, an allocation of 18.8 billion is envisaged, variously distributed among all the measures of the Transition Plan 4.0, for the two-year period 2020-2022 alone. 

It was actually foreseeable that the endowment of the soon to be adopted Budget Law could be lower than that envisaged by the 2021 Budget Law, considering that the last Maneuver could also rely on the extraordinary resources emanating from the Recovery Fund. In our opinion, however, the government's choice to no longer focus on the 4.0 Training Bonus and on the Tax Credit for ordinary tangible and intangible investments (not 4.0), which will therefore reachterminus in 2022 , unless changes emerge in parliament.

Below is an overview of the main incentive innovations for companies contained in the draft of the 2022 Budget Law of 10 November.


No extension in sight for the tax credit on non-4.0 ordinary capital goods (formerly "super-depreciation"), which was therefore expected to end on December 31, 2022, or June 30, 2023 in case of acceptance of the order and payment of advances at least equal to 20% of the acquisition cost by 2022. For 4.0 investments , on the other hand, functional to the technological and digital transformation of companies in an Industry 4.0 key, the tax credit is extended until 2025 , with possible investment queues by June 30, 2026, according to the following structure:


The extension of the R&D Innovation and Design tax credit, introduced by the Budget Law 2020 and amended by the Budget Law 2021, is foreseen, up to 2025 (for R&D activities even up to 2031) with decreasing rates but maximum benefit rates. sometimes increased, as follows:

At the moment, no time extension has been envisaged for the increased R&D tax credit for the South, introduced by the Relaunch Decree (DL 34/2020) for 2020 and extended until 2022 by the 2021 Budget Law.


No extension in sight, beyond 2022, not even for the SUD tax credit. The Government has, however, made corrective measures without which the bonus would have risked being stranded for its last year of validity, in light of the adoption of the new 2022-2027 Regional Aid Charter, which is currently not covered by the incentive regulations. By virtue of the draft 2022 maneuver, as last amended, it will be necessary to refer to the 2014-2020 Regional Aid Charter as regards the incentive intensities and the 2022-2027 Regional Aid Charter as regards the eligible areas , i.e. assisted areas of the regionsCampania, Puglia, Basilicata, Calabria, Sicily, Sardinia and Molise , eligible for the derogations provided for by Article 107, paragraph 3, letter a) , of the Treaty on the Functioning of the European Union, and the assisted areas of the Abruzzo region , eligible for the derogations provided for in Article 107 (3) (c) of the Treaty on the Functioning of the European Union. Abruzzo therefore remains the only region in transition that is only partially admissible.


In order to ensure continuity of the measures to support the productive investments of micro, small and medium-sized enterprises , the refinancing of Sabatini is envisaged. In the latest version of the Maneuver bill, the refinancing amounted to 900 million up to 2027 ; these are lower amounts than in the previous draft, in which 1,080 million were foreseen until 2026. In addition, more restrictive methods of access to the contribution are restored: lump-sum disbursement will be allowed only for loans up to 200,000 euros .


To support the internationalization of Italian companies through SIMEST , 8.2 billion are allocated until 2026 . From 2022 to 2026, each year, the L.394 / 81 fund will have 1.5 billion euros available for subsidized loans . At the same time, 150 million euros per year are received for the same period, for the granting of non-repayable co-financing in favor of "initiatives characterized by specific purposes" or addressed to "sectors or geographical areas deemed to be priority".


The 2022 Budget Bill allocates another  3 billion, up to 2027,  for the Guarantee Fund for SMEs. In particular, the Budget Bill confirms the Fund's extraordinary regime until 30 June 2022 , with some changes. From 1 January 2022, for small loans up to € 30,000, the coverage of the guarantee will drop from 90% to 80%. Furthermore, starting from April 1, 2022, a commission will be paid for the issue of the guarantee, thus eliminating the gratuity. The 2022 maneuver also outlines the operating methods of the Guarantee Fund starting from 1 July 2022.


In order to facilitate the adaptation of the national production system to European policies in the fight against climate change, the Fund for supporting industrial transition has been set up in the forecast of the Ministry of Economic Development with an endowment of 150 million euros. starting from the year 2022 . Facilitations can be granted to companies , with particular regard to those operating in energy-intensive sectors, for the realization of investments for energy efficiency, for the reuse for productive uses of raw materials and materials. recycled, as well as for the capture, sequestration and reuse of CO2.


A revolving fund has been set up with an endowment of 840 million for each of the years from 2022 to 2026 and of 40 million euros starting from 2027 . The Fund is intended to finance interventions in favor of private and public entities, aimed at contributing to the achievement of the objectives established in the context of international agreements on climate and environmental protection to which Italy is a party. The Fund may take on venture capital; provide indirect and direct financing ; provide guarantees . The Fund can also intervene in co- financing with European financial institutions, multinational and supranational financial institutions, multilateral development funds.


For the revaluation / realignment of intangible assets referred to in article 110 of the August Decree (DL 104/2020), the actual impact on public finances was initially underestimated by the legislator. To meet the concrete financial needs for the incentive measure in question , the draft Budget Law 2022 provides that the deduction of the greater value is diluted over 50 years , except for the payment of a substitute tax in order to be able to make the deduction. to an extent not exceeding one eighteenth of the cost or value, pursuant to article 103 of the TUIR. The supplementary substitute tax is commensurate with that provided for by article 176 of the Tuir  (12% on the part of the higher values ​​included in the limit of 5 million euro, 14% on the part of the higher values ​​that exceeds 5 million euro and up to 10 million euro and 16% on the part of the higher values ​​that exceed 10 million million euros), net of 3% of the replacement for the revaluation.

Against the unexpected extension of the tax discount, companies are granted the possibility of revoking, even partially, the 3% revaluation, with the return of the installment of the replacement already paid.