In recent years, tax credits for investments in capital goods have been among the most widely used tools for Italian companies to support innovation, digitisation, and the upgrading of production processes. Starting in 2026, however, the outlook will shift considerably. Under the 2026 Budget Law, the credit will slowly be brought to a close and replaced by a new mechanism: a fiscal surcharge on the purchase price of goods, known as hyper-amortisation or super-deduction.

This article explains how the capital goods tax credit works, which spending meets the criteria for support, the deadlines businesses need to meet, and – above all – what changes in 2026, including how the updated hyper-amortisation regime operates and which firms can benefit.

What's in this article?

• What is a tax credit for capital goods?
  
• How does the tax credit for capital goods work?
  
• Capital goods tax credit for 2025: Eligible investments and deadlines
  
• 2026 change: From tax credit to the return of hyper-amortisation
  
• Who can benefit from hyper-amortisation as of 2026
  
• Hyper-amortisation: How it is applied and timeframe
  
• Advantages of hyper-amortisation for Italian SMEs
  
• How Stripe Tax can help
  

What is a tax credit for capital goods?

A tax credit for capital goods is a fiscal concession measure that allows companies to recover part of the cost of purchasing depreciable resources utilised in manufacturing. This incentive grants credit that businesses can offset using the F24 form.

To fully understand the measure, it is helpful to start with the definition of capital goods: these are tangible or intangible resources used by the company on a long-term basis to carry out its economic activity. These are not assets intended for resale, but rather tools required for the production of goods or the provision of services.

Some of the most common examples include:

• Industrial machinery
  
• Installations
  
• Equipment
  
• Hardware
  
• Software
  
• Automation systems
  

How does the tax credit for capital goods work?

The way credit for capital goods works is relatively simple on a conceptual level, yet requires careful attention during the operational phase. The enterprise makes an eligible investment, determines the creditable sum due based on the asset type, and uses it to net levies owed.

From a tax perspective, the credit:

• Does not count as a taxable income
  
• Does not affect the Italian regional tax on productive activities (IRAP)
  
• Can be applied exclusively to counterbalance fiscal liabilities via the F24 form
  

Compared to the depreciation of capital goods, the main upside is the more rapid recovery of the tax benefit. Instead of deducting the cost over several financial years, the company obtains an immediate credit, as provided by law.

Fiscally credited spending for depreciable assets, therefore, offer a valuable tool for managing cash flow, especially during periods of growth or digital transformation.

Capital goods tax credit for 2025: Eligible investments and deadlines

A central consideration is the eligibility window for the relief. Businesses can use the 2025 tax credit for capital goods exclusively to purchases completed by 31 December 2025. A completion window is available until 30 June 2026, so long as:

• The supplier accepts the order by 31 December 2025
  
• By the same date, a minimum deposit of 20% of the purchase price has been paid
  

This rule matters for organisations mapping out complex investments or those facing extended delivery times. In practical terms, financial and contractual planning by 2025 is key to avoiding losing the tax break.

From an operational standpoint, it is worth maintaining documentation demonstrating:

• The order date
  
• The supplier's formal acceptance
  
• Payment of the advance
  

2026 changes: From tax credit to the return of hyper-amortisation

Pursuant to the 2026 Budget Law, the framework for levy incentives for productive investments in Italy will change significantly. The tax credit for capital goods, as we have known it in recent years (Transition Plans 4.0 and 5.0), will be gradually phased out and replaced by a different approach that imposes a levy on the cost of depreciable assets. In other words, as of 2026, there will no longer be any mention of credit for offsetting, but instead hyper-amortisation or super-deduction.

The difference is not just in terminology, but also in structure. With a tax credit, the company would accrue an amount that could be used directly on the F24 form to compensate for taxes and contributions, irrespective of profits (within certain limits). As of 2026, though, companies will be able to deduct a sum exceeding the holding's actual purchase price for fiscal purposes, thereby reducing taxable revenue over time.

Comparison between tax credit (until 2025) and hyper-amortisation (as of 2026)

How the new hyper-amortisation mechanism works

The new hyper-amortisation, in turn, works by uplifting the property's recognised fiscal value. For instance, if you purchase a machine for €100,000 and the regulation sets a 180% increase, the deductible value for tax purposes will not be €100,000, but €280,000. This rise does not translate into an upfront gain, yet is recovered gradually, following the ordinary depreciation rates set out for that type of asset.

A fundamental condition applies: the fiscal savings arises solely when the company generates taxable income. Without profits – or with very low earnings – larger deductions do not translate into real savings, unlike tax credits, which businesses can use to offset liabilities.

Cost increase brackets

Article 1, paragraph 427 of the 2026 Budget Law introduces a bracketed system for cost increases that depends on the total spend amount. Specifically:

• For investments up to €2.5 million, the applicable increase is 180%
  
• For investments between €2.5 and €10 million, the increase drops to 100%
  
• For the portion between €10 and €20 million, the increase is equal to 50%
  

This structure makes the incentive particularly attractive for medium to large expenditures, but requires careful assessment of tax sustainability over the medium term. It is also worth noting that, compared to initial assumptions, legislation appears to be moving toward a consistent uplift, without higher percentages specific to "green" spending.

Timeframe for taking effect

The new hyper-amortisation holds to investments made between 2026 and 30 September 2028, as provided for by Article 1, paragraph 427 of the 2026 Budget Law (Law 199/2025).

Another relevant factor involves the origin of the assets covered by the provision. Starting in 2026, eligibility for the hyper-amortisation system will also depend on where producers make the resources: they must manufacture them within the European Union or the European Economic Area (EEA). Furthermore, the current lists of qualifying assets will no longer carry over automatically. The 2026 Budget Law assigns the task of defining updated categories of eligible assets, tangible and intangible alike, to subsequent implementing decrees. As a result, businesses can no longer rely on prior rules and have to assess each expenditure under the new regulatory structure.

Who can benefit from hyper-amortisation as of 2026

As of 2026, hyper-amortisation will not target specific categories of taxpayers; instead, it will operate based on defined conditions tied to the investment itself and the firm's fiscal position. Unlike a tax credit for capital goods, the new mechanism does not grant a benefit that is automatically and immediately cashable. Still, it operates solely by gradually raising tax deductions.

From a subjective point of view, the hyper-amortisation regime can be applied:

• By companies residing in Italy

• By the permanent establishments of non-resident entities

Legal form does not determine access to the regime: sole proprietorships, partnerships, and corporations can all qualify, as long as they engage in a commercial activity.

Compared to the past, however, the ability to generate taxable earnings takes on a central role. Because hyper-amortisation increases deductible amounts rather than granting an offsettable credit, the positive effect materialises purely when the business results in assessable profits in the periods following the funding. Enterprises with structural losses or very low margins might not be able to take full advantage of the gain, despite having eligible investments.

From an objective point of view, the use of hyper-amortisation is subject to specific requirements:

• The purchased asset must belong to a category qualifying for relief, as future implementing decrees under the 2026 Budget Law will define, with separate classifications for tangible and intangible properties.

• Any technological criteria set forth in the law must be complied with.

• Manufacturers must produce it in a member state of the EU or in a country within the EEA.

Companies that are considered "in difficulty" pursuant to European state aid rules, such as those subject to insolvency proceedings or in liquidation, are excluded.

Hyper-amortisation: How it is applied and timeframe

One of the main differences compared to the fiscal credit for capital goods concerns the application methods. With hyper-amortisation, there is no need to submit a preliminary request or to follow a centralised reservation procedure, as seen in other incentives available on a first-come, first-served basis. The benefit is taken directly when determining taxable revenue by increasing the asset's depreciable cost.

Based on the regulatory framework outlined in Article 1, paragraphs 427 et seq. of the 2026 Budget Law, it operates through the standard tax amortisation approach.

In practice, the company:

• Treats an investment as eligible for tax relief as of 1 January 2026

• Enters the resource into capital assets

• Applies the growth in purchase price recognised for tax purposes under the law

• Deducts the increased value progressively through ordinary amortisation rates

In terms of documentation, it is important to:

• Retain contracts, invoices and technical documents related to the asset

• Demonstrate compliance with fiscal incentive requirements

• Correctly report the maximum deduction on tax returns

Regarding timing, current guidance indicates:

• That hyper-amortisation will apply to investments carried out from 2026

• A window that could run through 30 September 2028, unless future implementing decrees revise the schedule

These implementing acts will be decisive in definitively clarifying procedures, timeframes and formal requirements.

Advantages of hyper-amortisation for Italian SMEs

For Italian small and medium-sized enterprises (SMEs), the return of hyper-amortisation represents an incentive with characteristics very different from those of a tax credit for capital goods, but no less attractive. The main upside is the substantial fiscal leverage on productive expenditures: deducting more than the actual cost incurred can result in a significant reduction in taxable income in the medium to long term.

This mechanism particularly benefits SMEs:

• With stable earnings

• Mapping out structural, long-term investments

• Operating in manufacturing, industrial or technological sectors

Another advantage lies in the predictability of the gain. After completing the investment and confirming its eligibility for relief, the business can accurately estimate the tax impact on later annuities. Hyper-amortisation, therefore, serves as a planning tool rather than a source of instant liquidity.

How Stripe Tax can help

The transition from tax credit to hyper-amortisation makes accurate and structured tax management increasingly more important, especially for companies that operate in multiple markets or combine production, digital and e-commerce activities. In this context, understanding tax obligations, applicable taxes, and sales flows becomes key to properly supporting investment planning and overall regulatory compliance. At this stage, tax automation tools such as Stripe Tax can support businesses, simplifying the management of indirect taxes and reducing operational complexity.

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