Italy’s ZES Tax Credit: Updates & Deadlines for 2026 Investments
- Italian companies investing in the country’s southern regions are set to benefit from an extension of a tax credit program, with updated rules taking effect January 1, 2026.
- 124 of September 19, 2023, the tax credit has been prolonged through December 31, 2028, as outlined in Law No.
- The ZES Unica covers the assisted areas of Basilicata, Calabria, Campania, Molise, Puglia, Sardinia, and Sicily, as well as regions of Marche, Umbria, and Abruzzo.
Italian companies investing in the country’s southern regions are set to benefit from an extension of a tax credit program, with updated rules taking effect . The extension, formalized by a directive issued , builds on existing incentives designed to stimulate economic growth within the Zona Economica Speciale (ZES) Unica – the Single Special Economic Zone for Southern Italy.
Originally established under Article 16 of Decree-Law No. 124 of September 19, 2023, the tax credit has been prolonged through , as outlined in Law No. 199 of December 30, 2025 (the 2026 Budget Law). This extension aims to encourage investment in productive facilities, both existing and new, within the ZES Unica, which encompasses regions eligible for specific EU state aid derogations.
The ZES Unica covers the assisted areas of Basilicata, Calabria, Campania, Molise, Puglia, Sardinia, and Sicily, as well as regions of Marche, Umbria, and Abruzzo. These areas qualify under different articles of the Treaty on the Functioning of the European Union (TFUE) relating to regional aid.
Several key changes accompany the extension. Notably, the “vacatio” period – a previous gap between legislation and implementation – has been eliminated. The tax credit now applies to investments made throughout the entire calendar year, from to , of each year. The program also operates under a tiered spending limit, with €2.3 billion allocated for , €1 billion for , and €750 million for .
Companies seeking to utilize the tax credit must follow a two-step process. First, they must submit a preliminary communication to the Italian Revenue Agency outlining planned and incurred expenses. This communication window opens in the spring of each year. Second, a final communication, certifying actual expenses incurred by , is required in the following year. The credit is utilized through a compensation mechanism, as defined by Decree Law No. 241 of July 9, 1997, and must adhere to the regulations outlined in EU Regulation (EU) No 651/2014 (the GBER).
The tax credit is cumulative with de minimis aid and other state aid related to the same eligible costs, provided that the combined support does not exceed the maximum intensity or amount permitted under relevant European regulations. Studio Bonaccorsi notes that the theoretical tax credit rate can reach up to 60% for small enterprises in Sicily, although the effective rate in was around 45% due to high demand.
Eligible investments include machinery, plants, and equipment, as well as the purchase, construction, or expansion of instrumental real estate and land intended for production sites. A minimum investment of €200,000 is required. This makes the ZES Unica particularly attractive for companies planning new facilities or significant expansions.
A separate tax credit, specifically for agriculture, fishing, and aquaculture, has also been extended. This credit applies to investments made between and , with a total budget of €50 million for . Companies benefiting from this credit will need to submit communications to the Italian Revenue Agency between and , and again between and .
companies that invested between and may be eligible for an additional credit, potentially increasing their benefit to 75% of the initially requested amount, provided they did not utilize the Transition 4.0 tax credit. A communication window for this additional credit will be open between and .
The Italian Revenue Agency is expected to publish the percentage of allocation for the tax credits by of the following year.