New hyper-depreciation 2026: what changes with the budget law

TL;DR:

• Hyper-depreciation returns with increases up to 220% of the cost
• Replaces 4.0 and 5.0 tax credits from January 1, 2026
• Three investment brackets: 180%-100%-50% (220%-140%-90% for ecological transition)
• Investments valid from January 1 to December 31, 2026 (extension to June 30, 2027 with 20% down payment)

The 2026 budget law, currently under parliamentary approval with the goal of final green light by December 31, 2025, marks a radical turning point in tax incentives for businesses. From January 1, 2026, hyper-depreciation returns, an enhanced tax deduction that replaces the Transition 4.0 and 5.0 tax credits. The mechanism allows businesses to increase the tax cost of technological capital goods up to 220%, with estimated tax benefits of up to 52.8% of the investment for those focusing on the ecological transition.

How the new tax deduction works

The 2026 hyper-depreciation represents an off-balance sheet increase in the cost of capital goods, valid exclusively for income tax purposes and not for IRAP. Unlike the tax credit, which offered immediate recovery in compensation, this measure increases the annually deductible depreciation quotas, diluting the tax benefit over time.

The mechanism is structured on three progressive investment brackets:

• 180% increase for investments up to 2.5 million euros (estimated tax benefit with IRES at 24%: 43.2%)
• 100% increase for the portion between 2.5 and 10 million euros (benefit: 24%)
• 50% increase for the portion between 10 and 20 million euros (benefit: 12%)

Eligible assets are the same as those provided for by the current 4.0 and 5.0 tax credits: digital technologies, advanced robotics, interconnected production systems and assets for the self-production of renewable energy.

Strengthened increases for the ecological transition

Businesses investing in assets capable of generating certified energy savings access even higher deduction percentages. The legislation requires the investment to guarantee a reduction in energy consumption of the production site of at least 3%, or a reduction in consumption of the involved processes of at least 5%.

In questi casi le aliquote di maggiorazione salgono a:

• 220% up to 2.5 million euros (IRES tax benefit: 52.8%)
• 140% from 2.5 to 10 million euros (benefit: 33.6%)
• 90% from 10 to 20 million euros (benefit: 21.6%)

For businesses planning significant investments in digitalization and sustainability, Gruppo AQ offers specialized tax consultancy to quantify the actual advantage and structure the investment to maximize deductions, also evaluating cumulability with other benefits such as the Nuova Sabatini.

When does the facility apply?

Hyper-depreciation applies to investments in capital goods made from January 1 to December 31, 2026. An extension to June 30, 2027 is provided for investments “booked” by December 31, 2026, provided that the company pays a down payment equal to at least 20% of the acquisition cost by that date.

The relevant moment to consider the investment as made is that of the delivery or shipment of the good, or for goods made internally, the moment they are ready and available for use. This tight timing obliges companies to carefully plan purchases and the relative documentation.

Operational differences with previous incentives

Unlike the tax credit, hyper-depreciation is a deduction that reduces taxable income, not a credit to be offset. This means that the actual tax advantage depends on the IRES rate (24%) and the company’s ability to generate sufficient taxable income over the depreciation years.

The increased deduction applies to ordinary depreciation quotas and finance lease payments, but only for income tax purposes, excluding IRAP. The increase must be managed through downward variations in the tax return, without modifying the statutory values of the balance sheet.

A critical aspect concerns netting: if the investment benefits from other facilities (such as capital grants or the Nuova Sabatini), the deductible cost must be reduced proportionally. This operational complexity requires accurate tax planning to optimize the mix of facilities.

What changes for SMEs?

For small and medium-sized enterprises, the 2026 budget law is not limited to hyper-depreciation. The Nuova Sabatini is refinanced with additional funds to support the purchase of machinery, plants and software also through leasing. SMEs in the Mezzogiorno can also count on the extension of the Single SEZ tax credit, with allocations of up to 4 billion euros for investments until 2028 and rates up to 45%.

The strategic combination of hyper-depreciation, Nuova Sabatini and territorial tax credits can generate significant tax benefits. Gruppo AQ supports businesses in building integrated investment plans, optimizing access to different lines of subsidized financing and verifying the compatibility of de minimis and State aid regulations.

When is it convenient to anticipate or postpone the investment?

The choice between using the 4.0 tax credit (booking by December 31, 2025) or waiting for the 2026 hyper-depreciation depends on multiple factors. Companies with a need for liquidity or with small investment amounts might prefer the 4.0 credit, while those planning large investments for several years and who can sustain longer recovery times could maximize the advantage with hyper-depreciation.

A factor that is often underestimated is financial sustainability: hyper-depreciation reduces the tax burden only if the company generates sufficient taxable profits over the depreciation years. For start-up companies or those with low margins, the immediate tax credit may be more suitable.

Strategic consultancy by Gruppo AQ includes analysis of expected cash flows, simulation of tax scenarios and evaluation of the impact on corporate profitability, to identify the most effective solution with respect to the company’s growth objectives.

In short

• The 2026 hyper-depreciation replaces the 4.0 and 5.0 tax credits with increased tax deductions up to 220%
• Applies to investments in technological capital goods and for renewable energy from January 1 to December 31, 2026
• Base rates 180%-100%-50%, strengthened to 220%-140%-90% for investments with certified energy savings
• Unlike the tax credit, the advantage is spread over the years of depreciation of the asset
• In 2026, 4.0 credit (for 2025 bookings) and hyper-depreciation (2026 investments) temporarily coexist

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Did you know that

• Hyper-depreciation was already in effect from 2016 to 2019 with rates up to 250%, before being replaced by the Transition 4.0 tax credits in 2020
• The actual tax benefit of hyper-depreciation at 180% with IRES at 24% is equal to 43.2%, higher than the previous 4.0 credit of 20%
• The 2026 budget law also eliminates the rewarding IRES provided for companies that reinvest profits and hire
• In the three-year period 2026-2028, the banking sector will contribute approximately 9.5 billion euros through the increase in IRAP from 4.65% to 6.65%
• The Incentive Code, which entered into force on January 1, 2026, unifies and digitalizes all procedures for accessing facilities for businesses
• The tight timing of hyper-depreciation (basically one calendar year) forces companies to take quick decisions, unlike the previous tax credits that covered multi-year periods

FAQ

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Sources

• Rete Agevolazioni – Hyper-depreciation 2026: percentages and operational rules
• FISCOeTASSE – Hyper-depreciation 2026: all the rules
• Finera – Hyper-depreciation 2026: complete guide on the deduction for investments
• Ministry of Enterprises and Made in Italy – Tax credit for investments in capital goods
• Sky TG24 – 2026 Budget: calendar and approval process in Parliament
• Rete Agevolazioni – Comparison between super-depreciation, hyper-depreciation and tax credits
• ECNews – 2026 budget bill: the moment of making the investment
• Italia Avanti – 2026 Budget: five opportunities for businesses