Superbonus 110 and credit transfer with multiple communications. In case of several interventions admitted to the superbonus, for each of them it is necessary to send three separate forms to the Revenue Agency.
In summary, this is the clarification of the Revenue Agency put in black and white with the reply n ° 784 of 18 November.
Answer n ° 784 of November 18: more interventions with more communications to the tax authorities?
With the answer n ° 784 of 18 November, the Revenue Agency analyzes the situation in which the property is subject to works partially admitted to the sismabonus 110 and partially to the eco-bonus 110. Bonuses both attributable to the superbonus 110, pursuant to Article 119 of Legislative Decree 34 / 2020, Relaunch decree.
Specifically, the Applicant owns a building consisting of 5 real estate units, of which 3 are category A / 3 dwellings, while the others consist of a category C / 1 shop and a category C warehouse / cellar. /2. On a category A / 3 real estate unit, the applicant intends to carry out local anti-seismic interventions as well as energy saving interventions. Replacement of boiler, windows and doors.
To this end, it asked the Revenue Agency whether, in the case of credit transfer or invoice discount, for the aforementioned interventions, two separate forms for communicating the option should be sent to the Revenue Agency, one for anti-seismic interventions and one for energy efficiency interventions, or only one showing the sum of the amounts relating to the two interventions as the amount subject to discount or sale.
The opinion of the Revenue Agency
As it is known, by March 16 of the year following that of incurring expenses / carrying out works, the taxpayer must communicate to the Revenue Agency, with specific model, any Superbonus 110 options, credit transfer or invoice discount.
The same date applies to the other building bonuses.
The model was updated on 12 November after the entry into force of Legislative Decree 157/2021, the so-called “Anti-fraud decree”. Soon after it was the online channel reopened to communicate the options in question.
Having said that, considering that, in the present case, the applicant intends to carry out both the anti-seismic interventions and the energy efficiency interventions for the replacement of the air conditioning system and the replacement of windows and doors on the real estate unit of which it is the owner, he himself must send three separate forms to the Revenue Agency. For the communication of the option for the so-called “discount on invoice” or for the assignment of credit. That is, a different form for each intervention that will be carried out.
The indication is the result of the instructions for completing the aforementioned model. In fact, the instructions provide that in the “Type of intervention” field, the taxpayer indicates the identification code of the intervention for which the communication is being made. Distinguishing, in particular, between interventions on common parts and on single real estate units and, specifically, between “energy efficiency interventions”, “anti-seismic interventions in seismic zone 1, 2 and 3” and “other interventions”.
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