Training 4.0: the bonus changes its appearance for SMEs 

The 4.0 Training Bonus was introduced by the 2018 Budget Law and subsequently extended with amendments by the 2019, 2020 and 2021 Budget Laws, in order to support the training of employees for the acquisition or consolidation of skills in technologies relevant to technological and digital transformation of businesses.

In the explanatory report to the recently adopted Aid Decree 

(Law Decree no. 50 of 17 May 2022, containing " Urgent measures in the field of national energy policies, company productivity and investment attraction, as well as in the field of social policies and the Ukrainian crisis " )

It is specified that, with the aim of providing an answer to the " serious lack of professional skills adequate to the processes of technological and digital transformation, to which the measures of the Transition Plan 4.0 refer ", a system of qualification of the subjects providing employee training activities , subject ofTraining 4.0 tax credit referred to in paragraph 211 of article 1 of the 2020 Budget Law.

The amendment therefore aims to raise the quality of the 4.0 training system , guaranteeing correspondence between the needs of the companies benefiting from the tax credit and the training activities provided. To this end, certification of the results achieved in terms of acquisition and consolidation of skills is envisaged.

It should be remembered that, by virtue of the 2020 Budget Law, starting from 2020, the tax credit is attributed:

• for small businesses , to the extent of 50% of eligible expenses , with a maximum annual benefit limit of € 300,000;
• for medium- sized enterprises , to the extent of 40% of eligible expenses , with an annual maximum limit of € 250,000;
• for large companies, to the extent of 30% of eligible expenses , with an annual maximum limit of € 250,000.

The amount of the tax credit is in any case increased for all companies, without prejudice to the maximum annual limits, to 60% in the event that the recipients of eligible training activities fall within the categories of disadvantaged or very disadvantaged employees, as defined by decree of the Minister of Labor and Social Policies of 17 October 2017.

Article 22 of the Aid Decree provides that, in order to make the process of technological and digital transformation of small and medium-sized enterprises more effective , with specific reference to the qualification of personnel skills , the tax credit rates of 50% ( for small businesses) and 40% (for medium-sized businesses) provided for in Article 1, paragraph 211, of the 2020 Budget Law, for employee training costs aimed at acquiring or consolidating skills in relevant technologies for the technological and digital transformation of companies, they increased to 70% and 50% respectively , provided that the training activities are provided by subjects identified by decree of the Minister of Economic Development to be adopted within thirty days from the date of entry into force of the decree (18 May 2022) and that the   results relating to the acquisition or consolidation of the aforementioned skills are certified in the manner established with the same Ministerial Decree.

With reference to training projects launched after the date of entry into force of the Aid decree that do not meet these conditions, the tax credit measures decreased to 40% and 35% respectively. A double track is therefore introduced, pre and post Aid Decree. 

It seems unusual that a change in the dynamics relating to the incentive in question is introduced a few months after its termination, given the current absence of extensions of the incentive beyond 2022 (rectius: tax period in progress as of 31 December 2022); it is hoped that the Aid Decree will bring the incentive towards confirmation also for 2023 at least.

According to the forecasts of employment and professional needs in Italy in the medium term 2021-2025 by Unioncamere and ANPAL, the estimate for the period 2021-2025 of the need for personnel with the ability to use at least intermediate digital skills , such as the use of technologies internet, of visual and multimedia communication tools, is between 2 million and 2.1 million employed, ie about 57% of the total need .

In this context, a facility that adequately encourages the enhancement of human capital in a 4.0 perspective appears essential.

In its very first years of validity, the Training 4.0 bonus did not have the hoped-for success and a radical rethinking of the measure proved necessary . Thanks to the 2020 Budget Law, the severe constraints relating to the condition concerning the stipulation and filing of company or territorial collective agreements with the competent territorial labor Inspectorate have been rendered inoperative, no longer necessary for the purposes of recognizing the tax credit. .

2021 Budget Law

Lastly, the 2021 Budget Law, in article 1, paragraph 1064, has extended the objective scope of the incentive to cover almost all the costs of the training course , with disruptive scope for the benefit of companies. The main limit of the original formulation of the 4.0 training tax credit lay, in fact, in the narrow objective scope of the subsidized costs , up to 2020 confined to the costs of the personnel involved in the training activities, as a learner or teacher.

The 2021 Budget Law, on the other hand, admits the eligibility of all the expenses provided for by article 31 , paragraph 3, of Regulation (EU) no. 651/2014 of the Commission of 17 June 2014. In particular, the following costs are eligible for the subsidy:

• personnel expenses relating to trainers for the hours of participation in training;
• operating costs relating to trainers and training participants directly related to the training project, such as travel expenses, materials and supplies directly related to the project, depreciation of tools and equipment for the share to be reported to their exclusive use for the training project;
• the costs of consultancy services related to the training project;
• personnel costs relating to participants in the training and indirect overheads (administrative costs, rent, overheads) for the hours during which the participants attended the training.

Training activities concerning the following technologies are eligible for the tax credit : big data and data analysis; cloud and fog computing; cyber security; simulation and cyber-physical systems; rapid prototyping; visualization systems, virtual reality (VR) and augmented reality (AR); advanced and collaborative robotics; human machine interface; additive manufacturing (or three-dimensional printing); internet of things and machines; digital integration of business processes.

The training activities must concern the following areas:

• sales and marketing;
• informatica;
• production techniques and technologies .

For the purposes of eligibility for the tax credit, the costs must be certified by the person in charge of the statutory audit or by a professional registered in the Register of statutory auditors. For companies not required to carry out the statutory audit, an additional tax credit of up to 5,000 euros is envisaged to cover certification costs.

With a specific declaration made by the legal representative of the company, the attestation of effective participation in the training activities that can be facilitated must be issued to each employee .

For the purposes of subsequent checks, the companies benefiting from the tax credit are required to keep a report illustrating the organizational methods and contents of the training activities carried out.

In addition, the name registers of the training activities must also be kept .

The tax credit must be indicated in the tax return relating to the tax period in which the expenses were incurred and in the returns relating to the subsequent tax periods until its use is concluded.

For the sole purpose of allowing the Ministry of Economic Development to acquire the information necessary to assess the progress, dissemination and effectiveness of the subsidy measure , the companies that make use of the tax credit are required to notify the Ministry of economic development , through the model envisaged by the directorial decree of 6 October 2021 . With reference to the training activities carried out in the tax period subsequent to the one in progress at 31 December 2019, the communication form - Section A - must be sent by 31 December 2021. With reference to the expenses incurred in the tax periods eligible after the aforementioned tax period, the communication form - Section B - must be sent by the date of submission of the tax return referring to each tax period in which the investments are made