Unified SEZ tax credit for southern Italy: extension to 2028 and potential territorial expansion

One of the most significant changes introduced by the draft Budget Law concerns the potential inclusion of the Marche and Umbria regions within the scope of the incentive scheme, regions classified as “in transition” under the proposed legislation, which would regard such inclusion as a strategically significant opportunity.

The measure, transmitted to the Chamber on October 16 2025, if its legislative process is successfully completed, would extend the benefit provided under article 16 of Decree Law 124/2023 and prolong its applicability from January 1 2026 to December 31 2028, within the newly established expenditure limits of 2,3 billion for 2026, 1 billion for 2027, and 750 million for 2028.

The provisions of the decree 17 May 2024, where compatible, continue to apply. All companies may access the tax credit -regardless of their legal form or accounting regime- already operating or newly established within the unified ZES. As already established in the past, certain specific sectors remain excluded, including the steel, coal and lignite industries, the transport sector (apart from warehousing and transport-support activities) and related infrastructure, the production, storage, transmission and distribution of energy and energy infrastructure, broadband, as well as operators in the credit, financial and insurance sectors. Companies that are in liquidation or dissolution, as well as those considered to be in difficulty pursuant to EU regulation n. 651/2014 are also excluded.

For all other companies, the incentive remains fully available provided that the interventions fall within an initial investment project and concern new capital assets acquired either through ownership or leasing. Machinery, plants, and equipment are therefore eligible, as well as investments in land and operating properties. Quantitative limits also continue to apply: the investment must amount to at least 200.000 euro, may not exceed 100 million per individual project and the value of land and buildings may not exceed 50 per cent of the total eligible investment. Investments in operating assets are eligible for the incentive even when they concern properties previously used by the assignor or by other parties for the conduct of an economic activity.​​

The extension also confirms the procedural framework based on the double-notification mechanism. Each investment must be notified in advance to the Italian Revenue Agency between 31 March and 30 May of the year in which it is carried out, indicating both the expenses incurred since 1 January and those expected to be incurred by 31 December of the same year (for example, for investments made in 2026, the notification must be submitted between 31 march and 30 may 2026).

This first phase is followed, at the beginning of the following year, by a mandatory supplementary notification to be submitted between 3 and 17 January (for example, for investments made in 2026, the supplementary notification must be filed between 3 and 17 January 2027). At this stage the company must certify the investments actually carried out, attach the electronic invoices, indicate the amount of tax credit accrued and submit the accounting certification issued by the appointed auditor or, if not subject to statutory audit, by a statutory auditor or an audit firm. It is also provided that the investments reported in the supplementary notification may not exceed those declared in the initial notification.

The credit structure still includes the redetermination mechanism. If the subsidised assets do not become operational within the second tax period following their acquisition or completion, or if they are sold, disused, used for purposes unrelated to the business or transferred to production units different than those that generated the entitlement to the incentive within the fifth tax period after they enter into operation, the tax credit must be redetermined, excluding such investments. The same principle applies to assets acquired under leasing, regardless of whether the purchase option is exercised. Any tax credit used in excess of the recalculated amount must be repaid by making a payment no later than the deadline for the final settlement of income tax relating to the tax period in which the indicated circumstances occur.

The maximum amount of tax credit that each beneficiary may claim corresponds to the credit indicated in the supplementary notification, multiplied by the percentage that will be specified in a dedicated measure issued by the Italian Revenue Agency within ten days of the deadline for submitting the supplementary notifications. This percentage will be determined by comparing the total expenditure limit to the total amount of tax credits indicated in the supplementary communications.

The tax credit determined in this manner may be used exclusively to offset tax liabilities through the F24 form.

The extension fits into a clear strategy: supporting the economic revitalisation of Southern Italy and attracting new investments. The stability of the incentive and its extension through 2028 strengthen the conditions for sustainable and lasting growth in the areas concerned. For companies looking toward Italy, this represents a concrete opportunity that warrants careful consideration.