The text of the 2025 budget bill has landed in Parliament. The law, which is made up of 144 articles in total, contains a series of provisions aimed at businesses, grouped into 11 articles, including the establishment of a fund at the Ministry of Business and Made in Italy to provide a capital contribution to the businesses they have the tax credit was transferred to research and development. Then there is the introduction of contributions to facilitate the planning, implementation and management of ultra-broadband passive infrastructures in the white areas of the national territory. And they are expected extensions for some of the measures known and appreciated by companies, such as the Nuova Sabatini, the tax credit for the listing of small and medium-sized enterprises. There is also news for the tax credit for the Zes and the increase in the cost allowed as a deduction in the presence of new hires in 2027.
Let’s look at the most relevant measures in detail.
In the 2025 Budget Bill a contribution for companies that have benefited from the R&D tax credit amnesty
Article 74 of the 2025 Budget Bill provides for a capital contribution for subjects who have benefited from the research and development tax credit and who have joined the procedure for remitting the amount by 31 October 2024.
The procedure, we remember, was established by article 5 of the legislative decree of 21 October 2021, n. 146, converted, with amendments, by law 17 December 2021, n. 215 to allow those who requested the tax credit in good faith for activities which were then found not to be included in the scope of the tax relief return the tax credit unduly used without penalties.
The Budget Bill provides that the contribution is commensurate in percentage terms with the amount paid within the maximum limits of the expected expenditure. To this end, Mimit will be created a background with a financial endowment of 60 million of euros for the year 2025, of 50 million euros for the year 2026 and of 80 million euros for the year 2027.
The ministry itself, in concert with the Mef, will establish the methods of disbursement of the contribution, the percentages of the same and its installments with a decree which must be issued within 60 days from the entry into force of the law.
Resources for Nuova Sabatini
Additional resources also for New Sabatinithe measure aimed at supporting the investments of Italian SMEs for the purchase (including leasing) of machinery, equipment, plants, capital goods for production use, hardware, software and digital technologies.
For the measure, art.75 of the DDL provides for an increase of:
- 400 million euros for the year 2025
- 100 million euros for the year 2026
- 400 million euros for each of the years from 2027 to 2029
Extension of the tax credit for the listing of small and medium-sized enterprises
Also extended tax credit for the listing of small and medium-sized enterprises. The incentive, established by law 27 December 2017, n. 205aims to support SMEs that begin a procedure for admission to listing on a regulated market or in multilateral trading facilities of a Member State of the European Union or of the European Economic Area.
The tax credit, recognized within the limit of 50% of consultancy costs incurred by the company, is dedicated to activities carried out until 31 December 2027 and can be used within the overall limit of 6 million euros for the year 2025 and 3 million euros for each of the years 2026 and 2027.
Budget Bill, the provisions for the Zes tax credit
Article 77 of the provision instead provides for the extension of the Zes tax credit. The instrument designed to support companies that purchase capital goods intended for existing production structures or that are set up in the Special Economic Zone for the South will be extended not only to goods purchased until 15 November 2024, but also to those purchased from 1 January 2025 to 15 November 2025.
The overall spending limit, which was set at 1.8 million for 2024, drops to 1.6 million euros in 2025. For 2025, businesses that want to take advantage of the tax credit must communicate to the Revenue Agency, between 31 March and 30 May, the eligible expenses incurred and scheduled until November 15, 2025.
Thereafter, by December 2, 2025, they must send a supplementary communication which certifies the realization of the investments and contains the details of the accrued tax credit, accompanied by documentation such as electronic invoices. The communication forms to be sent will be approved by the Director of the Revenue Agency within 30 days of the law coming into force.
The percentage of actual credit will be determined by the Revenue Agency based on the overall spending limit. As regards the usable credit, however, paragraph 4 of the art. 77 specifies the following:
the maximum amount of the tax credit usable by each beneficiary is equal to the amount of the tax credit resulting from the supplementary communication referred to in paragraph 2, second sentence, of this article multiplied by the percentage made known by order of the director of Revenue Agency, to be issued within ten days of the deadline for submitting supplementary communications. This percentage is obtained by comparing the spending limit to the overall amount of tax credits indicated in the supplementary communications referred to in the second period of the aforementioned first period.
If the tax credit is lower than the maximum envisaged, the regions will be able to use resources from the European cohesion programmes to encourage investments.
Ultra-broadband, up to 220 million contributions per year for white areas
Article 76 establishes specific interventions for promote the spread of ultra-broadband in the so-called “white areas” of the national territory, or areas with poor internet coverage.
To this end, it is envisaged that the Minister of Business and Made in Italy, in collaboration with the Minister of Economy and Finance, can provide financial contributions of up to 220 million euros per year for each of the years 2027 to 2029.
These contributions are intended to cover the needs motivated by the body responsible for the implementation of the necessary passive infrastructure design, construction and management projects. Furthermore, any financial resources not used based on real needs must be returned to the state budget.
New hires, extension of the increase in tax deductions
Article 70 concerns the extension of increase in the cost admitted as a tax deduction linked to new hireswhich aim to encourage employment through tax breaks linked to new hires, with specific methods of calculating tax advances for the indicated tax periods. This extension applies for the tax period following the one in progress on 31 December 2024 and for the following two years.
The provisions of the legislative decree of 30 December 2023, n. 216, are extended to the increases in employment recorded at the end of each of these tax periods compared to the previous year, following the limits and conditions specified in the decree itself.
Regarding the determination of tax advances, the text specifies that:
a) for the tax period following the one in progress on 31 December 2025 and for the following two, the tax of the previous period is assumed to be that which would have been determined by not applying article 4 of the legislative decree of 30 December 2023, no. . 216;
b) for the tax period following the one in progress on 31 December 2024 and for the following two, the provisions referred to in paragraph 1 of this article are not taken into account.
The text of the 2025 Budget Bill
Below is the text of the 2025 Budget Bill limited to the section dedicated to measures for businesses only.
Measures for Businesses Maneuver-2025
