Since 21 July 2026, Italian companies can confirm their bookings for the iperammortamento 2026 on the GSE portal, declaring a down payment of at least 20% on each asset. The booking window itself opened on 12 June, five weeks after the implementing decree of 7 May. That closes months of uncertainty which, says Sabrina Lombardo of the tax firm Pirola Pennuto Zei, led companies to put off investment decisions. So, does a machine bought in 2026 still earn a hyper-depreciation? Yes, and so does qualifying software.
It’s a tax incentive for capital goods, yes, but it doesn’t pay out like the Transizione 4.0 and 5.0 credits it replaced. So we’ll start with who can claim it, and on what. The rates, the GSE filings and Nuova Sabatini come next, then a €600,000 example with the sums done, and a checklist. New to all this? Start from the beginner’s map, from zero to a first round.
In short
- The iperammortamento 2026 increases the tax cost of new 4.0 goods (Annexes IV and V of Law 199/2025) and of renewable self-generation plants, for investments made from 1 January 2026 to 30 September 2028. It replaced the Transizione 4.0 and 5.0 tax credits.
- The increase is 180% of the cost up to €2.5 million, 100% from €2.5 to €10 million and 50% from €10 to €20 million. At the standard 24% IRES rate, the first band saves up to €43.20 of tax per €100 invested, over the depreciation years.
- The goods no longer have to be made in the EU or the EEA: Decree-Law 38 of 27 March 2026 removed that condition for all investments from 1 January 2026.
- Everything runs through the GSE: a preventive communication, confirmation within 60 days with at least 20% paid on each asset, and completion by 15 November 2028, backed by a sworn technical appraisal and an auditor’s certification.
Iperammortamento 2026: what replaced Transizione 5.0
The ministry, MIMIT, calls it continuity with the Transizione 4.0 and 5.0 plans. The mechanism is the old one, though. Instead of a tax credit you offset against payments, you get a ‘maggiorazione’: the asset’s cost is increased, for income tax only, when you work out depreciation or finance-lease instalments. MIMIT’s own verb is ‘reintroduces’. Before the credits took over in 2020, Italy’s hyper-depreciation worked this way.
Where does it sit in law? Article 1, paragraphs 427 to 436, of the 2026 budget law (Law 199 of 30 December 2025). MIMIT and the Ministry of Economy signed the implementing decree on 7 May 2026. Before that, Decree-Law 38 of 27 March 2026 (converted by Law 88 of 22 May 2026) scrapped the rule that goods be made in the EU or the European Economic Area. The change covers every investment from 1 January 2026.
Two consequences follow. The benefit arrives slowly, year by year, as you depreciate. And a deduction is only worth something if there’s taxable profit to deduct it from. A startup with a high burn rate, the cash it loses each month, may wait years to use it; the startup grants open in Italy this autumn often fit better. Nor is it a grant: nobody wires you money.
Britain does the opposite. Since 1 April 2023, a UK company that buys new plant and machinery can deduct 100% of the cost from that year’s profits. They call it full expensing. Faster, but never more than the price. Italy gives you more than the price, slowly. Weighing a British subsidiary too? Read our guide to expanding to the UK from Italy.
Who qualifies, and which goods count?
Businesses resident in Italy and Italian permanent establishments of foreign companies, whatever their legal form, sector or size, investing in new capital goods for production sites in Italy. Firms in liquidation or insolvency proceedings are out, as are those under disqualifying sanctions (Legislative Decree 231/2001) or not in order with workplace safety and social contributions. Professionals are out too, since the measure runs through business income, and for flat-rate (forfettario) businesses the way taxable income is calculated leaves no room for it.
Three families of goods qualify:
- Annex IV, physical 4.0 goods in four groups: machines controlled by computer systems or sensors (machine tools, laser and waterjet cutters, presses, assembly and welding machines), quality and sustainability systems, human-machine interfaces and workplace safety devices, and equipment for processing, storing and transmitting data. In the first group, a machine needs five mandatory features, CNC or PLC control and interconnection with the factory’s systems among them, plus two of three more.
- Annex V, intangible goods: software, platforms, applications, algorithms and digital models, from product design to production planning and extended reality. They must be capitalised assets; a SaaS subscription is an operating cost and stays out.
- Renewable self-generation plants for your own consumption, storage included, sized at no more than 105% of the site’s energy needs on the previous year’s average consumption.
The rates by investment band
The increase falls as the investment grows, slice by slice, like income tax brackets.
| Slice of the investment | Increase in deductible cost | Extra IRES saved per €100 of that slice (at 24%) |
|---|---|---|
| Up to €2.5 million | 180% | €43.20 |
| Over €2.5 million, up to €10 million | 100% | €24.00 |
| Over €10 million, up to €20 million | 50% | €12.00 |
| Over €20 million | None | €0 |
A €4 million plan, then, gets 180% on its first €2.5 million and 100% on the other €1.5 million: €6 million of extra deductions, worth €1.44 million at 24%. A €25 million plan stops at €17 million of extra deductions. And timing matters: the increase counts from the tax year in which your completion communication reaches the GSE, provided the asset is up and running that year.
A worked example: a €600,000 machining centre
Say a precision-engineering company near Brescia, an SRL, the Italian limited company, orders a five-axis machining centre for €600,000 in November 2026. CNC-controlled, connected to the factory’s production software: Annex IV, first group. The company is invented. The rules aren’t.
- November 2026: the preventive communication goes to the GSE, listing the machine, its cost, its depreciation rate and the expected interconnection date.
- Within 60 days of the GSE’s positive reply: the order is confirmed with at least €120,000 paid, 20% of the price.
- Spring 2027: delivery and interconnection, then the sworn appraisal and the auditor’s certification of the costs.
- Before 31 December 2027: the completion communication. From tax year 2027 the company deducts €1,080,000 more than normal depreciation, spread over the machine’s depreciation years.
Total value: €259,200 of IRES saved, 43.2% of the price, if the profits are there to absorb it. Financing part of it with Nuova Sabatini? Then the Sabatini contribution comes off the base first, and the saving shrinks a little.
Deadlines and documents: the GSE steps
The GSE (Gestore dei Servizi Energetici) runs the platform, in its client area, with SPID or CIE. Each step has a clock.
- Preventive communication: one or more per production site, with company data, type and amount of the planned investments, and for each asset the completion and interconnection dates. Investments made since 1 January 2026 can be reported too.
- Confirmation, within 60 days of the GSE’s positive reply: each asset confirmed or dropped, with at least 20% of its cost paid. For leasing, the signed contract and the lessor’s purchase order count. No new assets can be added, and costs can only go down.
- Completion, when the investment is done and by 15 November 2028 at the latest: you declare that you hold the interconnection appraisal and the accounting certification.
- Monitoring: updates every January and June while you use the deduction, with the depreciation plan.
The technical proof is a sworn appraisal (perizia tecnica asseverata) or a certificate from an accredited body, covering the asset’s features and its interconnection. The costs need a certification from a statutory auditor (revisore legale). One trap sits at the end. Sell the asset, or move it to a production site abroad, even your own, during the benefit period, and you lose the rest of the deduction, unless that same tax year you replace it with a new asset of similar or better technology.
Can you combine it with Nuova Sabatini and other incentives?
Yes, within limits. Nuova Sabatini, the ministry’s contribution towards the interest on a bank loan or lease for machinery, is the obvious partner. If the bank wants more security, see how Italy’s SME guarantee fund works. Other national or EU aid on the same goods is allowed, but the base for the increase is taken net of grants and contributions received, and the total can’t exceed what you actually spent.
One overlap is ruled out. Did the supplier accept your order and get 20% by 31 December 2025, with delivery by 30 June 2026? Then that investment stays under the old 4.0 tax credit. Developing technology yourself rather than buying it? Look at the R&D tax credit for the work and the patent box for income from protected IP. If you’d like a second pair of eyes on the plan before you book, our public funding service is the place to start.
Checklist before you sign the order
- Check each asset against Annex IV or V, line by line, with the supplier’s technical sheet.
- Get in writing how the machine will connect to your production or management software.
- Send the preventive communication once the plan is firm. You then have 60 days from the GSE’s reply to confirm, with 20% paid.
- Line up the appraiser and the statutory auditor early. Fix their fees before any work starts.
- Using Nuova Sabatini or other aid? Net it out of the base in your plan.
- Run the numbers on profits: in which years will the extra deductions actually cut your tax?
- Put 15 November 2028 in the diary, and the January and June updates after it.
Is there an iperammortamento in 2026?
Yes. Invest between 1 January 2026 and 30 September 2028 and you’re inside the window set by Law 199/2025. The detailed rules came with the decree of 7 May 2026, and the GSE has taken bookings since 12 June 2026.
What replaced Transizione 5.0?
The iperammortamento. MIMIT presents it as the continuation of Transizione 4.0 and 5.0, replacing their tax credits with an increase in the deductible cost of the goods.
Do the machines have to be made in the EU?
No longer. Decree-Law 38/2026 deleted the EU or EEA production requirement, and the change applies to investments made from 1 January 2026.
Does software qualify?
Yes, if it’s listed in Annex V and recorded as a fixed asset. Subscriptions such as SaaS are operating costs and don’t qualify.
Can I use it together with Nuova Sabatini?
Yes. The base for the increase is taken net of the Sabatini contribution, and the combined aid can’t exceed the cost of the investment.
This article is general information, not legal or tax advice. Rules and GSE procedures change: check the decree and the GSE’s instructions, or ask a professional, before you order or file.
Adaxit
Planning a machinery or software investment between now and 2028? Tell us what you’ll buy and when, and we’ll look at which incentives fit.
Sources
- MIMIT, Nuovo Piano Transizione 5.0: Iperammortamento, last updated 22 July 2026
- GSE, Nuovo Piano Transizione 5.0, consulted 9 October 2026: overview, who can apply, how to apply, calculating the benefit, documents
- Gazzetta Ufficiale: Law 30 December 2025, n. 199, GU n. 301, ordinary supplement n. 42, with Annexes IV and V (GU text); Decree-Law 27 March 2026, n. 38, GU n. 72, converted by Law 22 May 2026, n. 88, text of article 7
- Agenzia delle Entrate, Corporate income tax (IRES), consulted 9 October 2026
- Assosoftware, analysis of the implementing decree, June 2026; ANCE, GSE platform and implementing decree, 12 June 2026
- Sabrina Lombardo (Pirola Pennuto Zei), Iperammortamento 2026: efficacia dell’incentivo e limiti della nuova disciplina, dirittobancario.it, 21 July 2026; FiscoeTasse, Legge finanziaria 2026: l’iperammortamento, 6 January 2026
- GOV.UK, Full expensing and 50% first-year allowance, consulted 9 October 2026
For information only: this is not investment advice or a public offer.



