Let’s start 2022 with good news that dispels any residual doubts regarding the accumulation of incentive measures financed with resources under the National Recovery and Resilience Plan with other concessions: these incentives can in fact be cumulated, provided of course not to cover the same costs. This is definitively specified by Circular N. 33 of the State Accounting Office dated 31/12/2021 and signed by the State Accountant General Biagio Mazzotta.
The issue arose following above all Circular no. 21 of the same State Accounting Office dated 14 October 2021, which ordered the Technical Instructions for the selection of PNRR projects.
In particular, the reference of the Accounting Office to the “obligation of absence of the so-called double financing, that is that there is no duplication of the financing of the same costs by the device and other Union programs, as well as with ordinary resources from State budget “.
—
Many had interpreted this instruction, which referred to the European Regulation 2021/241, as a substantial prohibition of accumulation between any incentives financed with the resources of the PNRR and other concessions, of whatever nature they were, even if financed with state resources.
Double financing and accumulation are different concepts
In the new clarification circular, the Accountant Mazzotta emphasizes instead that double financing and cumulation are two distinct and non-overlapping principles. The first was and remains forbidden, while the second is foreseen and allowed.
—
But what is the difference between the two concepts?
—
As Mazzotta explains, “the prohibition on double financing, expressly provided for by European legislation, requires that the same cost of an intervention cannot be reimbursed twice from public sources of financing, even of a different nature”.
Cumulability, on the other hand, “refers to the possibility of establishing a synergy between different forms of public support for an intervention, which are thus” cumulated “to cover different portions of a project / investment”.
The latter case is envisaged and permitted under the PNRR by art. 9 of the EU Regulation 2021/241, where it states
Support provided under the Recovery and Resilience Facility (RRF) is in addition to support provided under other Union programs and instruments.
Mazzotta therefore concludes that “it is therefore possible to accumulate different financial sources within a single project” …provided that such support does not cover the same cost“(Prohibition of double financing)”.
The circular also offers a practical example. “If a measure of the PNRR finances 40% of the value of a good / project, the remaining 60% can be financed through other sources, provided that the cumulation provisions applicable from time to time are respected and, overall, it is not exceeded 100% of its cost. In the latter case, part of the costs would in fact be financed twice and this case would be attributable to the so-called “double financing”, which is always forbidden “.
The rule also applies to the Transition Plan 4.0
The measures of the Transition 4.0 plan are among those most affected by this discipline. In fact, we recall that various incentives insist on the purchase of capital goods (eg the Nuova Sabatini or the tax credit for the South).
In the circular, the State Accounting Office specifies – if ever there was a further need – that “the above also applies to the PNRR measure Transition 4.0 which provides for the granting of a tax credit for companies investing in 4.0 technologies and in Research and development. In this case, where the investment is partially financed by other public resources, cumulation with the tax credit is allowed (up to 100% of the investment cost), exclusively for the part of the investment cost. not financed with other public resources “.
The text of Circular no. 33 of the State Accounting Office
Below you can read and download the full text of Circular no. 33 of the State Accounting Office
Circular-dated-31-December-2021-n-33
–
