2026 Budget Law: enhanced tax depreciation returns for digital and energy investments
December 30, 2025
The 2026 Budget Law reintroduced enhanced tax depreciation (Iperammortamento) for certain digital and energy investments made from 1 January 2026 to 30 September 2028. The incentive is not a tax credit: it increases the tax basis of eligible assets, thereby increasing deductible depreciation charges or finance lease payments for income tax purposes.
What is the new enhanced tax depreciation regime?
The measure reintroduces the logic of enhanced tax depreciation (Iperammortamento). It is not a tax credit that can be offset through the Italian F24 payment form, but an increase in the tax basis of eligible assets, affecting the deductibility of depreciation charges and finance lease payments for income tax purposes.
Which investments are eligible?
The incentive applies to investments made from 1 January 2026 to 30 September 2028. It covers new tangible and intangible assets supporting technological and digital transformation, as listed in Annexes IV and V to Law No. 199/2025, as well as certain investments for self-production and self-consumption of energy from renewable sources.
How large can the tax uplift be?
For eligible tangible assets and self-production investments, the uplift is structured by investment brackets and may reach 180% for investments up to EUR 2.5 million. Effective access to the incentive requires compliance with the applicable technical requirements, interconnection requirements where relevant, and the documentary obligations laid down by the implementing rules.
What should the business do?
- assess in advance whether the planned assets fall within Annexes IV and V;
- estimate the tax benefit based on the investment bracket and the company’s capacity to use the additional deductions;
- coordinate tax planning with ordering, delivery, commissioning and interconnection dates;
- plan the required technical and accounting documentation from the outset of the investment.
What are the main legal and administrative references?
Legal references: Law No. 199 of 30 December 2025, Article 1, paragraphs 427-436. The measure was subsequently implemented and coordinated through the Interministerial Decree of 7 May 2026 and later MIMIT Directorial Decrees.