As established by Article 4 of Legislative Decree No. 216/2023, and as extended by Article 1, paragraphs 399-400, of Law No. 207/2024, an increase in the cost allowed as a deduction for new hires of personnel is provided for the tax periods 2024, 2025, 2026 and 2027.
In particular, for holders of business income and for those engaged in the arts and professions who make new hires of permanent employees, a 20% tax surcharge on labour costs for IRES/IRPEF purposes is recognised; in order to benefit from the deduction, both of the following conditions must be met
- employment increase at the end of the tax periodi.e. the number of permanent employees at the end of the financial year must exceed the average number of permanent employees employed at the end of the previous year;
- total employment increase at the end of the tax periodi.e. the total number of employees, including those on fixed-term contracts, at the end of the financial year must exceed the average total number of employees at the end of the previous year.
The determination of the 20% tax surcharge will be calculated on the lesser amount between:
- the actual cost of new permanent hires;
- the increase in total personnel costs compared to the previous period.
In addition to new open-ended employment contracts, also considered are the conversions of contracts from fixed-term to open-ended from the date of the contract conversion. Finally, Paragraph 400(b) of Article 1 of the aforementioned Budget Law 2025 provides that for the determination of the advance payments due for the following tax period, this increase in the personnel cost admitted as a deduction is not taken into account.
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.