Transition plan 5.0 3D printers: it is reality with the PNRR decree

The tax credit for companies that join the Transition 5.0 plan is now underway. With the PNRR decree published in the Official Journal, the set of benefits aimed at promoting energy efficiency and digitalisation of companies can begin.

In the two-year period 2024-2025, companies will be able to use the incentives, in the form of tax credits, of the Transition 5.0 plan . In fact, last February 26th Mimit approved the decree law Pnr r (DL no. 19/2024) published in the Official Journal no. 52 of 2 March 2024 with a series of important measures for companies aimed at encouraging the efficiency of their production processes, reducing energy consumption and orienting them towards sustainability and green development, concepts which until now have often remained on paper. The benefit is specifically regulated by article 38 of the aforementioned legislative decree.

The 5.0 transition plan is financed by funds equal to 6.3 billion euros and has been in force since 2 March 2024. The purpose of the measure is to support the digital and energy transformation process of businesses.

Transition 5.0 is the result of the proposal that Italy brought to the EU which was approved by Commission on 24 November and by the Council on 8 December . These are structural innovations that impact the Italian Pnrr, which has meanwhile gone from 191.5 to 194.4 billion euros, to 614 from 527 objectives, from 6 to 7 missions, with the introduction of the EU Repower chapter. The reforms that Italy will have to implement go from 69 to 66. The new Pnrr allocates 2.9 billion euros to support the production system for the ecological transition , net zero technologies and the competitiveness and resilience of strategic production chains. All investments are aimed at facilitating the energy efficiency of production processes, self-consumption of electricity, the circular economy and the efficient use of resources, but all these measures depend on implementing decrees which have not yet been published.

Efficiency and energy saving

The activities covered by the subsidy must produce results measured in terms of energy efficiency and energy savings . To this end, it will be necessary to respect one of the following two conditions: in the case of investments in 4.0 goods , the energy savings achieved in the target processes must be equal to at least 5% compared to previous consumption for the same processes; while in the case of activities not linked to specific target processes, the reduction in final energy consumption must be at least 3%. The intensity of the benefit will be modulated on at least one specific three rates based on the results achieved. The project must be accompanied by ex ante certification by a professional who certifies the validity of the work and ex post a further certification must verify that the parameters are actually respected. The implementing decree must arrive in the first months of 2024.

Objectives and types of eligible investments

The objectives of the Transition Plan 5.0 are:

• Increase energy efficiency and promote the adoption of self-production of renewable energy in businesses , with the aim of achieving a cumulative saving of 0.4 Mtoe in energy consumption in the period 2024-2026.
• Support the digitalisation of businesses , through the adoption of innovative technologies, such as advanced robotics, artificial intelligence, the Internet of Things, 3D printing and cloud computing.
• Promote the competitiveness of Italian companies on international markets .

This will be an incremental tax credit compared to that already provided for by Transition 4.0 . The concessional rates are not yet defined, but according to the previews provided they will reach a maximum of 20% and can be added to those of Transition 4.0. Therefore, the maximum rate for companies that will be able to add the two incentives will be 40%, to which two further lower rates could be added for a total maximum of 45%.

The intensity of the benefit and therefore the percentage of tax credit recognized will vary based on the improvements achieved in terms of energy efficiency at company level (at least 3%) or at the level of the production process involved (at least 5%).

Incentive rates

The incentive provided by the Transition Plan 5.0 is a tax credit, which can be used to offset taxes owed or in the form of a discount on the fee due to the supplier of capital goods.

The tax credit rate varies depending on the type of investment and the degree of energy saving or innovation achieved.

In particular, the rates are as follows:

• Investments in capital goods for energy efficiency
  • 50% of the cost, if the energy saving is at least 30%
  • 30% of the cost, if the energy saving is at least 20%
• Investments in capital goods for innovation
  • 40% of the cost, if the good falls into the 4.0 goods category
  • 20% of the cost, if the good does not fall into the 4.0 goods category

Requirements to access the tax credit

To access the tax credit, investments must be made by 31 December 2026. Furthermore, capital goods must be new and purchased from suppliers established in Italy.

Eligible investments

Going into the merits of the expenses eligible for the relief, these must be incurred between 1 January 2024 and 31 December 2025. Therefore, all companies that have already made investments from the beginning of 2024 to today, if in possession of the requirements established by the law , they can rest assured: they will be able to request the tax credit of the Transition Plan 5.0.

The investments subject to the tax credit will be those meeting the requirements of the national Industry 4.0 plan, i.e. those that satisfy the now 5+2 mandatory requirements.

But these requirements will not be sufficient to obtain the benefit. In fact, investments must necessarily (under penalty of exclusion) guarantee a minimum energy saving of 3% if compared to the entire production structure or 5% if compared to a specific production process affected by the investment.

In this minimum range you will obtain a tax credit equal to:

• 35% for investments up to €2,500,000.00 ;
• 15% for investments included between €2,500,000.00 and €10,000,000.00 ;
• 5% for investments included between €10,000,000.00 and €50,000,000.00 .

The maximum allowable investment is equal to €50,000,000.00.

The decree also extended the applicability of the tax credit to two categories of software (as indicated in Annex B - Law 232/2016), necessary for monitoring company consumption.

The obligations

On the front of the fulfillments there is no shortage of news regarding the Capital Goods 4.0 tax credit. To obtain the tax credit of the Transition Plan 5.0 it will be necessary to include the regulatory reference to the art. on the transport documents, invoices and all documentation relating to investments. 38 paragraph 15 of the DL Pnrr of 02/03/2024.

Compared to the draft, the Legislative Decree n. 19 assign a leading role at the GSE . Before actually starting the project, it will be necessary to notify the Energy Services Manager and appoint an independent expert who will have to certify the reduction in consumption by the various percentages.

Appraiser certification

At the conclusion of the investments, a new communication will be made, with a second certification from the expert, obligations aimed at certifying the completion of the investments.

To these ex ante and ex post certifications, Legislative Decree no. 19 adds the communication concerning the description of the investment project among the necessary obligations. This communication will then be forwarded by the GSE to the Ministry of Business and Made in Italy.

In addition, it will also be necessary a report from the statutory auditor , as has happened to date for the tax credit for Research and Development and Training 4.0 activities.

In summary, the following documents will therefore be necessary:

• 2 communications to the GSE (before and after making the investments);
• 2 expert certifications (before and after making the investments);
• 1 auditor's report (upon completion of investments).

It seems clear that the will of the Legislator was to make this new tax credit more controllable and this translated into more complex management of the entire process.

Fortunately, an additional tax credit of up to €10,000.00 has been provided for the expert's certifications and, for companies not obliged to carry out a statutory audit of accounts, an additional tax credit of up to €5,000.00 for the expert's report. reviewer.

Focus on certifications to obtain incentives

To obtain the incentive it will also be necessary to obtain an "ex ante" certification , issued by an independent evaluator who will have to certify that the project complies with the eligibility criteria relating to the reduction of total energy consumption. A second "ex-post" certification, once the investment is completed, will certify the actual realization of the investments in compliance with the provisions of the ex-ante certification.

The subjects authorized to issue the certifications should be the same ones authorized to produce the technical-economic certification provided by the Fund for the support of the Industrial Transition for the part relating to energy efficiency:

• EGE (Expert in Energy Management) accredited UNI CEI 11339
• UNI CEI 11352 accredited ESCOs
• ISO50001 accredited organisations
• Geologists, engineers and industrial experts registered with the relevant professional association, or who are part of the staff of the company requesting the energy diagnosis.

In the latter case, engineers and industrial experts would be authorized to draw up both assessments for the 4.0 and 5.0 tax credit, while the others would only be authorized to prepare 5.0 assessments. The maximum subsidized ceiling for each investment should amount to 50 million euros .

Differences with the 4.0 transition plan

To better understand the scope of the innovations introduced by the Transition 5.0 plan, it seems useful to summarize the previous situation, which will also continue in parallel with the new incentive program in cases where those who want to access it will not be able to implement interventions that produce savings energy at least equal to 3% of the production structure or 5% of the processes affected by the project .

The Transition 4.0 plan was financed as part of Mission 1 - Component 2 "Digitalisation, innovation and competitiveness of the production system" of the PNRR, with a financial allocation of 13.381 billion euros (to which are added 5.08 billion euros of the Complementary Fund) and the objective of supporting the digital transformation of businesses by encouraging private investments in goods and activities to support digitalisation through the recognition of a tax credit for: purchase of material goods; purchase of 4.0 intangible assets (e.g. advanced software); purchase of traditional intangible assets (e.g. basic software); R&D&I activities; 4.0 training activities. The 4.0 tangible and intangible assets subject to the incentive regime are specified in the two Annexes (A and B) prepared by the then Ministry of Economic Development.

Conclusions

The tax credit envisaged by the 5.0 transition plan can now be said to be a reality thanks to the PNRR Decree. Only a few implementing decrees are still missing, but the doubts regarding its operation can now be said to have been overcome. The process is in fact now almost complete.

The plan aims to incentivize the energy efficiency of companies by making improvements compared to the previous 4.0 transition. It is aimed at all companies present on the national territory without distinction, and provides a differentiated rate system depending on the type of intervention you want to implement.

Although the advantages outweigh the disadvantages, there are some gaps in the Transition 5.0 plan, especially with regard to digitalisation, and especially on the training front.

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