The 2026 Transizione 4.0 framework provides a 180% increase of the tax-depreciable cost of eligible Industry 4.0 machinery and equipment.
This means that an asset purchased for 100 is tax-depreciated as if it had cost 280.
For an Italian limited company (S.r.l.), this increased deduction translates into an overall tax saving of approximately 43.2% of the asset’s cost, spread over the depreciation period, through a lower IRES and IRAP taxable base.
The incentive is fully compatible with the ZES tax credit, up to the maximum aid intensity allowed by the Regional Aid Map for the relevant type of business and geographical area.
This is a particularly relevant tax measure for companies investing in technologically advanced, interconnected plants, machinery and production lines.
Nature of the incentive
The 4.0 hyper depreciation:
- is not a grant
- is not a tax credit
- is not subject to ranking or application procedures
It is a pure tax mechanism allowing companies to deduct, over time, an amount higher than the actual purchase cost of the asset.
Eligible assets
Only tangible capital assets listed in Annex A of the Transizione 4.0 regulation qualify, provided they meet specific technological requirements, including:
- control through CNC and/or PLC systems
- interconnection with factory IT systems
- automated integration with logistics systems or supply chain
- advanced human-machine interface
- continuous monitoring of working conditions and process parameters
The essential and non-negotiable requirement is the interconnection of the asset with the company’s IT system.
Only capital goods manufactured within the European Union are eligible.
Essential conditions to qualify
To benefit from the incentive, both formal and substantive requirements must be met:
- order formally accepted by the supplier
- payment of at least 20% advance
- asset put into operation
- effective interconnection with the company system
- sworn technical report (asseverated expert appraisal) certifying compliance with legal requirements
Concrete tax effect – practical example
Example for an S.r.l. subject to IRES and IRAP:
- Machinery cost: €100,000
- Tax-depreciable value: €280,000
- Additional deductible amount: €180,000
Applying IRES 24%:
€180,000 × 24% = €43,200
The total tax saving over the depreciation period is therefore €43,200 against a €100,000 investment.
The benefit is distributed over the useful life of the asset.
Operational procedure
Proper access to the incentive requires:
- preliminary verification that the asset meets 4.0 requirements
- correct drafting of orders and contractual documentation
- management of the interconnection process
- obtaining the sworn technical appraisal
- proper accounting and tax reporting
Studio Bonaccorsi assists companies throughout all these phases, coordinating supplier, technical expert and tax management.
Who should consider this incentive
Particularly relevant for companies that:
- modernize or automate production lines
- introduce CNC machinery
- integrate production processes with IT systems
- make structural investments aimed at technological efficiency
For machinery manufacturers and suppliers
This measure represents a strong commercial argument for:
- machinery manufacturers
- industrial system integrators
- suppliers of plants and production lines
The firm supports clients in preparing technical information materials to be shared with potential buyers, clearly explaining the connected tax benefit.
Essential FAQs
Is this a tax credit?
No. It is an increased tax-deductible depreciation base.
Is it compatible with the ZES tax credit?
Yes, up to the maximum aid intensity allowed by EU regional aid rules.
Is the technical appraisal mandatory?
Yes, it is essential.
What if the asset is not interconnected?
The incentive does not apply.
When does the benefit start?
From the year the asset is operational and interconnected.
Does it apply to software?
Only if strictly connected and complementary to a 4.0 tangible asset.
Where must the assets be manufactured?
Within the European Union.
Conclusion
The 4.0 hyper depreciation is one of the most effective tax tools available to reduce IRES and IRAP burden on investments in technological innovation.
Correct technical, documentary and tax structuring is crucial to fully benefit from the incentive.