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Hyper-Amortization for investments made from 1 January 2026

published on 12 January 2026 | reading time approx. 7 minutes

The 2026 Budget Law (Law No. 199 of 30 December 2025) introduces new hyper-amortization rules for investments in capital goods made between 1 January 2026 and 30 September 2028, in line with the Transition 4.0 and 5.0 tax credit frameworks. For tax purposes, the increased deduction applies to the rise in the purchase cost of exclusively new assets manufactured in an EU Member State or in a country that is a party to the European Economic Area Agreement.

This increase is relevant only for tax purposes and applies to the calculation of additional depreciation and finance lease payments.

Unlike tax credits, hyper-amortization operates solely as an increase in deductible depreciation allowances. The benefit materializes only when there is sufficient taxable income; in the event of a tax loss, the additional deduction is not forfeited but carried forward to subsequent fiscal years until taxable profits are restored. This feature differentiates hyper-amortization from the 4.0 and 5.0 tax credits, which can be utilized even in the absence of taxable income.

Under the new rules, the acquisition cost of eligible assets will be increased at the following uniform rates, regardless of the asset category: 180 per cent for investments up to €2.5 million, 100 per cent for investments over €2.5 million and up to €10 million, 50 per cent for investments over €10 million and up to €20 million.

Depreciation must be calculated in accordance with Articles 102 and 103 of Presidential Decree No. 917 of 22 December 1986 (TUIR), and the additional depreciation rate — at 180 per cent, 100 per cent, or 50 per cent, depending on the investment amount—must be reported in the tax return. The same procedure applies to assets acquired under finance lease agreements.

The following table summarises the applicable surcharge percentages and the related tax savings (IRES):

Investment amount	Percent increase	Percent savings (IRES 24 per cent)
Up to €2.5 million	180	43,2
Over and up to €10 million	100	24,0
Over and up to €20 million	50	12,0

The regulation stipulates that the subsidy applies exclusively to the following types of assets.

With regard to tangible assets, these are new capital goods included in the updated annexes to the 2026 Budget Law (Annex III-bis), interconnected with the company's production management system or supply network. The updated annexes reflect technological advancements and introduce new categories, including:

Computing infrastructure for AI and simulation (HPC, edge computing, machine learning workstations);
Industrial connectivity infrastructure (private 5G networks, industrial Wi-Fi 6/7, TSN systems);
OT/IT cybersecurity infrastructure (industrial firewalls, IEC 62443-compliant IDS/IPS);
Advanced machine vision systems, exoskeletons, HVAC systems serving production processes.

Conversely, the following have been expressly excluded: personal computers, notebooks, tablets, printers, scanners, office peripherals, home or small office (SoHo) network equipment, and storage systems not integrated with operational processes.

With regard to intangible assets, Annex III-ter to the 2026 Budget Law has significantly expanded the scope of eligible intangible assets, aligning tax regulations with the evolution of enabling technologies. Newly eligible categories include:

Generative AI software, Large Language Models (LLMs), Agentic AI: tools capable of performing complex decision-making processes and generating content or code, which are now crucial for advanced automation, computational design and the optimisation of industrial flows;
MLOps platforms: environments that integrate the development, deployment and monitoring of AI/ML models, with versioning, audit and compliance features, essential for the scalable and traceable adoption of artificial intelligence;
Carbon footprint calculation and LCA analysis software: applications that enable the measurement of environmental impact throughout the entire product life cycle, instrumental for ESG reporting and compliance with the criteria of the EU Taxonomy Regulation;
Platforms for Digital Product Passports and IDS-RAM-compliant data spaces: systems that ensure interoperability and secure sharing of industrial data according to the standards of the International Data Spaces Reference Architecture Model, which are fundamental for the traceability and circulation of data in European digital markets;
Low-code/no-code platforms for rapid development of industrial applications: environments that enable even non-technical figures to create customized software tools, accelerating innovation in production and decision-making processes;
Advanced cybersecurity, digital twin and blockchain solutions for notarization and traceability: critical technologies for ensuring digital resilience, virtual replication of industrial processes and secure, immutable certification of data and transactions, with direct implications for compliance, security and business continuity.

Investments in new tangible assets for self-generation of renewable energy for self-consumption, including storage systems, are also eligible for subsidies.

With regard to photovoltaic systems, modules pursuant to Article 12(1)(b) and (c) of Decree Law 181/2023 will be eligible for hyper-amortization: this means that only modules produced in EU countries of type b) and c) (silicon heterojunction or tandem cells, high-efficiency bifacial modules) are eligible for the subsidy, with the exclusion of type a) modules (efficiency of at least 23.5 per cent).

Although it will be necessary to wait for the implementing decree, scheduled for 31 January, in principle, investments eligibility will be determined based on the accrual principle under Article 109 of the TUIR.

Essentially, for the purposes of hyper-amortization, for movable assets, the date of delivery or shipment will be relevant , or alternatively the date of transfer of ownership if later transfer of ownership if later, while for leased assets, the date of delivery to the lessee will be considered.

The date of the order or payment of deposits is not relevant, unless the investment has actually benefited from previous incompatible subsidies.

The measure is incompatible with the 4.0 tax credit. Assets reserved by 31 December 2025 with confirmed 4.0 benefits are excluded, even if acquired in 2026. Conversely, if the 4.0 application has been canceled due to resource exhaustion, such investments would still appear to be eligible for the new hyper-amortization.

The maxi-deduction applies to taxpayers with business income and investments in production facilities located in Italy. However, companies in voluntary liquidation, bankruptcy, compulsory administrative liquidation, composition without business continuity, or subject to insolvency proceedings, as well as those sanctioned under Legislative Decree 231/2001, are excluded. The benefit is also subject to compliance with workplace safety regulations and social security contribution obligations.

Notably, the scope has narrowed compared to previous versions: the additional surcharge for ‘green’ assets has been removed. Specifically, the current legislation has abolished the increased rates for such investments and/or those aimed at reducing energy consumption. There are no longer any enhanced rates (220 per cent, 140 per cent, 90 per cent) for investments that ensure a reduction in energy consumption within the production facility or related processes. Furthermore, the presumptive simplifications that previously allowed automatic access to increased rates in certain cases, such as the replacement of depreciated assets, ESCo projects, or high-efficiency photovoltaic systems, have also been eliminated.

Access to the benefit is not automatic: communications and certifications relating to eligible investments must be submitted electronically through a dedicated platform managed by the Energy Services Manager (GSE), using standardized forms that will be defined by an interministerial decree issued by the competent Ministries within 30 days of the law’s entry into force. This decree will also specify, among other things, the procedures for verifying the original requirement and the documentation needed for intangible assets.

Finally, if an asset benefiting from the subsidy is sold or transferred to production facilities abroad during the benefit period, the remaining quotas are preserved provided the asset is replaced within the same fiscal year by a new tangible asset with similar or superior technological characteristics. If the replacement asset costs less, the benefit continues only up to the amount of the new cost.