Reduced taxation of profits reinvested for the acquisition of new instrumental assets and/or the increase in employment
According to article 8 of the draft of 2019 Budget Law, under specific conditions a reduced tax rate will apply with reference to the reinvestment of profits.
In particular, change of legislation provides for the reduction of 9 percentage points of the applicable tax rate(s) for the quota of profits reinvested in the company and destined to the acquisition of new instrumental assets and the increase in employment. The mentioned reinvestments must be addressed to production structures located in Italy.
In fact, the new tax benefit will replace the tax amortization regime “Super ammortamento” as well as the Notional interest deduction benefit “Aiuto alla crescita economica (ACE)”, while article 10 of the draft of 2019 Budget Law, extend the tax amortization regime “Iper ammortamento” for a further tax period, even if in a reformulated version.
Tax payers interested by the reduction of the income tax rate(s)
The reduced tax rate(s) will be applicable for limited liability companies, members of partnerships and individual entrepreneurs, while professionals seem to be excluded.
Based on article 8, paragraph 4 of the Draft the reduced tax rate will apply also in case the tax consolidation regime is adopted and, according to paragraph 7, the reduction can also be cumulated with other tax benefits, except for those providing for a flat-rate regime in determining the taxable income.