FAQ Transition 5.0, clarifications from the GSE on: cumulation, documentation and eligible projects

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Emma Potter

Can be combined with other European benefits

One of the aspects covered in the FAQ concerns the possibility of accumulate the tax credit with other benefits provided by programs financed with European Union resources. Based on the Ministerial Decree Transition 5.0, in line with the Guidance on Recovery and Resilience Plans adopted by the European Commission on 31 May 2024, Cumulability is not permitted with other benefits that are part of programs or instruments financed at European level.

For example, it is not possible to cumulate the tax credit with measures financed or co-financed by the following funds:

  • European Regional Development Fund (ERDF)
  • European Social Fund + (ESF+)
  • Just Transition Fund (JTF)
  • National Recovery and Resilience Plan (PNRR)
  • European Agricultural Fund for Rural Development (EAFRD)

This implies that operators will have to carefully evaluate the sources of financing and verify that the benefits requested do not overlap with European resources.

Tax credit and combinability with national benefits

Despite the limitations mentioned above, the Transition Ministerial Decree 5.0 establishes that the tax credit is cumulative with other benefits financed with national resourcesas long as they refer to the same costs. However, there are some conditions: the sum of the benefits must not exceed cost incurred from the company.

Cumulability is not permitted with the existing incentives indicated below:

  • the Transition 4.0 tax credit;
  • the Special Economic Zone investment bonus (single SEZ – Southern Italy) of DL 124/2023extended to the Special Logistics Zone (ZLS) (art. 13 of Legislative Decree 60/2024).

Documentation and eligible projects

As for the necessary documentationthe GSE and the Ministry of Business have provided specific details on how to submit requests to access the benefits. Among the main requirements are the need to present detailed technical and economic documentation that justifies the investment and demonstrates its consistency with the objectives of the incentive.

Additionally, the eligibility criteria for projects. Among the investments allowed, particular attention was paid to interventions relating toenergy efficiency and to theself-production of energy from renewable sources.

Eligible projects

Projects eligible under the measure Transition 5.0 include investments started from 1 January 2024 and completed by 31 December 2025, through which an overall reduction in energy consumption of the production structure located in the national territory, to which the innovation project refers, was achieved, not less than 3 percent or, alternatively, a reduction in the energy consumption of the processes affected by the investment not less than 5 percent.

Investments must concern new material goods, instrumental to the operation of the businessinterconnected to company systems or the supply network (Annex A to law 232/2016), And intangible assets newhow software for energy management and energy efficiency (Annex B to law 232/2016).

They are also eligible investments in self-production of energy from renewable sourcesexcluding biomass plants e expenses for training in digital and energy technologieswithin 10% of the investment (up to 300 thousand euros).

However, some exclusions they concern assets such as vehicles, buildings, assets with a depreciation rate of less than 6.5%, and interventions that violate the principle of “not causing significant damage” to the environment (DNSH).

Photovoltaic systems

Eligible projects also include photovoltaic systemsbut only if i modules used are registered in a specific registeras required by the Decree-Law 9 December 2023, n. 181. While waiting for the register to be formed, facilities that use modules that comply with the requirements established by current legislation may be supported.

One is planned increase by 120% for modules with efficiency equal to or greater than 23.5%, and by 140% for bifacial modules with efficiency greater than 24%. However, to benefit from these surcharges, both the modules and the cells must be produced within the European Union.