Transition 4.0 tax credit: can also be used with debts registered in the role


With the recent response to ruling no. 451 of 1 July 2021 , the Revenue Agency made important clarifications regarding the "Industry 4.0" tax credit ; the related indications are expressly extended to other tax concessions, such as, for example, the 2015-2019 R&D tax credit and the SUD investment tax credit .

Due to the presence of overdue roles at his own expense, for IRES, VAT, IRAP taxes, the applicant asked to know if he can offset the "Industry 4.0" tax credit with his debts through Form F24 .

Revenue Agency intervened to clarify the scope of application of the prohibition of offsetting pursuant to Article 31, paragraph 1, of Legislative Decree 78/2010, which provides that, in the event of debts exceeding 1,500 euros, registered in the for state taxes and related accessories, and for which the payment term has expired, the offsetting of receivables relating to state taxes is prohibited up to the amount of the payables.

The financial administration has made it clear that the facilitated credits in question can in no way be traced back to the definition of "credit deriving from tax"; for this reason, with reference to these subsidized receivables, the aforementioned prohibition on offsetting does not apply for debts exceeding 1,500 euros, registered in the role for tax and related accessories, and for which the payment term has expired.

As clarified by circular letter no. 13 / E of 11 March 2011, the prohibition on offsetting does not apply to contributions and benefits granted for any reason in the form of a tax credit, even if they are indicated in the "Treasury" section of form F24.

These clarifications certainly add appeal to the measures of the Transition Plan 4.0 , the effects of which can already be traced in the Ucimu - Sistemi per Produrre survey on the state of health of the machine tools installed in Italy.

In the study, relating to the 2019 data compared to those of 2014, it emerged that, despite the fact that there are fewer factories in Italy, the number of machines installed is clearly increasing ; moreover, the average level of integration and automation of the installed machines has increased .

These are good results , which can certainly be improved over the next few years , given that there are still significant margins for improvement : the average age of the machines installed has grown from 12 years and 8 months to 14 years and five months and almost half of the machines have over twenty years of life.

Undoubtedly, the Plan will remain in vogue for another year and a half (rectius for capital goods until 30/6/2023), but it is hoped that it will be more long-lasting and acquire a structural character .

To date, the desired financial confirmation of the Complementary Fund to the PNRR has taken place, to complete the coverage of the Plan until 2022 . The conversion law (Law no. 101/2021) of Legislative Decree 59/2021 “Urgent measures relating to the complementary Fund to the National Recovery and Resilience Plan and other urgent measures for investments” was published in the Official Gazette of 6 July 2021. The Complementary Fund  allocates 5.08 billion euros for Transition 4.0. The resources, which are added to the 13.38 billion of the National Recovery and Resilience Plan (PNRR), will go to finance incentives for sectors that risk not aligning with the " Do No Significant Harm"(DNSH), which permeates the PNRR, in order not to cause significant damage to the environment, through the measures financed with the relative resources. The total budget allocated to the Transition Plan 4.0  by the Italian Recovery plan therefore exceeds 18.4 billion of euros .

The NACE sectors merged exclusively into the Complementary National Fundare as follows: 30 Manufacture of other means of transport; 22 Manufacture of rubber and plastic products; 29 Manufacture of motor vehicles, trailers and semi-trailers; 38 Waste collection, treatment and disposal activities; 41 Construction of buildings; 42 Civil engineering; 43 Specialized construction activities; 08 Other mining activities; 17 Manufacture of paper and paper products; 01 Plant and animal production, hunting and related services; 50 Transport of water; 19 Manufacture of coke and refined petroleum products; 20 Manufacture of chemical products; 51 Air transport; 24 Manufacture of base metals; 49 Land transport and transport by pipeline; 23 Manufacture of other non-metallic mineral products; 35 Supply of electricity, gas, steam and air conditioning