Non-repayable contributions in the support decree

In recent weeks, a large number of VAT number holders who have requested it have received credit for the grant provided for by Legislative Decree 41/2021, better known as the “Support Decree”. There is time until today, May 28, to submit an application.

The non-repayable contribution is due to all economic operators carrying out business activities, arts and professions, or to holders of agricultural income regardless of the atec code of the activity carried out and the accounting regime adopted.

The only requirements that the applicant must possess are: not having achieved revenues in 2019 – remuneration exceeding 10,000,000 euros and having suffered a decrease in turnover in 2020, calculated on monthly averages, of at least 30% compared to 2019.

The contribution must be calculated on the negative difference of the monthly averages by applying a coefficient between 60% and 20% depending on the amount of revenues / remuneration achieved in 2019.

Particular is the method of calculating the monthly average turnover 2019 for those who started the business from 01/01/2019; it must in fact be calculated with reference only to the months starting from the one following the opening of the VAT number. Example: VAT registration March 2019: Turnover from April 2019 to December 2019 divided by 9 (months from April to December). This average will have to be compared with the monthly average for the entire year of 2020 to verify that there has been a concrete decline in turnover. The contribution will therefore be calculated by applying the coefficients from 60% to 20%.

The contribution will be due to these subjects even in the absence of the decrease in turnover to the minimum extent foreseen (1,000 euros for natural persons and 2,000 for subjects other than natural persons).

Leaving out further details on the methods of identifying the beneficiaries, on those of calculating both the turnover and the contribution, it should not be overlooked that, with the methodology adopted (as has also happened for other covid aids), in the conviction of the legislator to have centered the method faster to identify the audience of recipients, the possibility was given to request and obtain the subsidy also to those who in fact could face the economic crisis, consequent to the covid, without contribution, leaving more resources available for those who, for example, were forced to close for a long time and to whom the contribution could be granted with a surcharge.

The reference is to those who are in possession of other income and at the same time have a VAT number. Think of the employee who also carries out self-employment activities. If this taxpayer has registered a decrease in turnover of more than 30%, he will be entitled to the non-repayable contribution even in the presence of an employee income such as to give sufficient guarantees of survival unlike the small entrepreneur whose only source of income is his own activities.

This also applies to those who have a VAT number and also have other types of income.

In the opinion of the writer, another condition for access to the contribution was imposed, such as, for example, a limit on the possession of other income.

Also the reference to turnover, as an entity against which to measure the possible decrease, lends itself to situations worthy of attention which, in some way, can open the way to unjustified discrimination.

Think of all the economic operators with a VAT number whose income is determined with the cash principle; this is often the case in which the costs are incurred in one year and the remuneration or fee is collected in the following year. Low-income tax periods (due to the manifestation of higher costs) and higher-income tax periods (due to the manifestation of higher revenues or compensation) may alternate. Assuming a concentration of costs and low turnover in 2019, while in 2020 the turnover increases only as a result of the collection of the remuneration related to the activity already carried out in 2019. Apparently there is no decrease in turnover but only due to the time lag between the the moment in which the costs are incurred and the moment in which the turnover is generated and revenues are achieved.

In conclusion, the need should not be overlooked that at the technical tables, where the rules are written, the presence of accountants is more than ever necessary who, with their contribution, can induce the political class to reflect on some aspects little known to it. . In this case it would have been possible to arrive at a more reasoned distribution of resources destined to support those who actually need them.

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