Hyperamortization 2026-2028 – New Transition Plan 5.0

The 2026 Budget Law introduced the new Hyper-amortization 2026 (New Transition Plan 5.0), This replaces the previous tax credit provided for by the Transition Plan 4.0/5.0.

The new concession consists of a increase in the cost of tax-deductible expenses of capital goods 4.0, allowing for a greater tax deduction and, consequently, a reduction in the IRES or the IRPEF over the amortization years.

The incentive applies to investments made from January 1, 2026 to September 30, 2028. and it concerns, in particular, the tangible and intangible assets that are functional to the technological and digital transformation of enterprises, identified in Annexes IV and V of Law no. 199/2025, as well as certain investments intended for the self-production and self-consumption of energy from renewable sources.

The proposed increases are:

  • 180% for investments up to € 2.5 million;
  • 100% for the quota from € 2.5 to € 10 million;
  • 50% for the share from € 10 to € 20 million.

 

To access the benefit, it is necessary that:

  • the good is new;
  • the good falls within the categories eligible for relief;
  • the investment is intended for a production facility located in Italy;
  • for the assets for which such a requirement is provided, the interconnection to the company systems is implemented;
  • the specific documentation and procedural requirements provided for by the regulations are respected, including the sworn technical report or equivalent certificate and the communications to be submitted through the GSE.

 

A notable innovation is the elimination of the restriction that limited the relief to goods produced within the European Union or the European Economic Area: from 2026, goods produced in countries outside the EU will also be eligible for relief.

Since the benefit operates through a greater deduction from the corporate income tax and not through an immediately usable tax credit, its convenience is particularly significant for companies that plan to generate taxable income in the years in which the higher depreciation rates will be deducted.

 

While remaining at your disposal for any doubts or requests for clarification, we would like to take this opportunity to extend our best regards to all.