Training bonus 4.0

Companies that incur expenses for training their employees in 4.0 technologies can benefit from a tax credit. The rules of the bonus were amended by the Budget Law 2021, which broadened the types of expenditure eligible for aid. The amount of the tax credit varies depending on the size of the company, from 30% to 60% of eligible expenses, with a maximum of €300,000 for small companies and €250,000 for medium and large companies.

Eligible for the Training 4.0 tax credit – established by the 2018 Budget Law (art. 1, paragraphs 46 to 56, Law no. 205/2017), amended by the 2020 Budget Law (Law 160/2019, art. 1, paragraphs 210-217) and, most recently, extended (until the current tax period ending 31 December 2022) and strengthened by the 2021 Budget Law (Law 178/2020, art. 1, paragraph 1064 letter l) – are all companies resident in the territory of the State, including permanent establishments of non-resident entities, regardless of:

  • by the legal form
  • the economic sector to which they belong (enterprises in the fishing, aquaculture and primary production of agricultural products sectors are also eligible)
  • size
  • the tax regime under which the company’s income is determined

The following are excluded:

  • companies in a state of voluntary liquidation, bankruptcy, compulsory administrative liquidation, arrangement with creditors without business continuity or other insolvency procedure provided for by the bankruptcy law, Legislative Decree 14/2019 (Code for business crisis and insolvency) or other special laws, or which have proceedings in progress for the declaration of one of these situations.
  • Companies subject to disqualification sanctions under Article 9(2) of Legislative Decree 231/2001.

Training activities aimed at acquiring and consolidating skills and knowledge in the following 4.0 technologies are eligible for the tax credit:

  • big data and data analysis
  • cloud and fog computing
  • cybersecurity
  • simulation and cyber-physical systems
  • rapid prototyping
  • visualisation systems, virtual reality (VR) and augmented reality (AR)
  • advanced and collaborative robotics
  • human-machine interface
  • additive manufacturing (or three-dimensional printing)
  • internet of things and machines
  • digital integration of business processes

The tax credit cannot be used for ordinary or periodic training organised by the company to comply with current legislation on health and safety in the workplace, environmental protection and any other compulsory training regulations.

The training activity:

  • must be intended for employees of the beneficiary enterprise. Employees are defined as staff with a subordinate employment relationship, including fixed-term contracts and apprentices. The State aid nature of the Training 4.0 tax credit prevents the widening of the pool of beneficiaries to personnel with an employment relationship other than an employee one (clarification provided by the Ministry of Economic Development during a conference held on 10 February 2021);
  • it must concern one or more of the following business areas: sales and marketing; information technology and techniques; production technologies (the sectors in which to carry out training are listed in Annex A of the 2018 Budget Law);
  • it can be organised directly by the company or provided by entities outside the company. In the latter case, only activities commissioned to:
    • entities accredited to carry out funded training activities at the region or autonomous province where the enterprise has its registered office or operational headquarters
    • public or private universities or related structures
    • subjects accredited by the interprofessional funds
    • entities in possession of quality certification according to European regulations
    • Higher Technical Institutes (ITS)

Lessons can be carried out in e-learning mode or online, if companies adopt control tools suitable to ensure, with a sufficient degree of certainty, the effective and continuous participation of the staff engaged in the training activities (Ministry of Economic Development, Circular 3 December 2018 no. 41208).

Following the amendment made by the Budget Law 2021, as of 1 January 2021, the following expenses are eligible for the tax credit:

  • personnel costs related to trainers for the hours they participate in training
  • operating costs related to trainers and training participants directly related to the training project, such as travel expenses, materials and supplies directly related to the project, depreciation of tools and equipment for the portion to be referred to their exclusive use for the training project. Accommodation costs are excluded, except for minimum accommodation costs necessary for participants who are disabled workers
  • costs of consultancy services related to the training project
  • personnel costs related to trainees and indirect overheads (administration, rent, overheads) for the hours during which the trainees attended the training

Any expenses relating to employees ordinarily employed in one of the business areas identified in Annex A to the 2018 Budget Law (Law No 205/2017) and participating as teachers or tutors in eligible training activities are also eligible.

Eligible expenses must be certified and attached to the budget.

Firms with audited financial statements are excluded from the certification requirement.

For companies that are not required by law to have their accounts audited, such certification must be issued by a statutory auditor or auditing firm.

For the expenses incurred to comply with the obligation to certify accounting documents, such companies may benefit from a contribution, in the form of a tax credit, equal to the expenses incurred and documented for the activity of certifying the accounts, up to a maximum limit of EUR 5,000 (without prejudice to the maximum annual limits).

The tax credit is granted to the extent of:

  • for small enterprises: 50% of eligible expenses, up to a maximum annual limit of €300,000
  • for medium-sized enterprises: 40% of eligible expenses, up to an annual ceiling of €250,000
  • for large enterprises: 30% of eligible expenses, up to an annual ceiling of €250,000

The measure of the tax credit is, however, increased for all enterprises, subject to the annual maximum limits, to 60%, if the recipients of the eligible training activities fall within the categories of disadvantaged or very disadvantaged employees as defined by the DM of the Ministry of Labour and Social Security (MLPS) of 17 October 2017.

Under that decree:

  • “disadvantaged employees” include persons who meet one of the following requirements:
    • they have not been in regular paid employment for at least 6 months, i.e. those who in the last 6 months have not carried out work attributable to a subordinate employment relationship lasting at least 6 months as well as those who in the last 6 months have carried out work in a self-employed or para-subordinate form from which derives an income that corresponds to gross tax equal to or less than the deductions due under Article 13 of the TUIR
    • are between 15 and 24 years old
    • they have not obtained an upper secondary education diploma or a vocational education and training qualification or diploma falling within the third level of the International Classification of Educational Levels, as well as those who have obtained one of the qualifications no more than two years previously and have not had a first regular paid job as defined in point a)
    • are at least 50 years old
    • are 25 years of age or older and are supporting a household on their own as they have one or more dependants as defined in Article 12 of the TUIR
    • are employed in sectors and professions characterised by a rate of inequality between men and women that is at least 25% higher than the average inequality between men and women, as identified annually by ministerial decree, and who belong to the underrepresented gender
    • they belong to linguistic minorities historically settled on the Italian territory and to those minorities officially recognised in Italy based on specific provisions and who demonstrate the need to improve their linguistic and professional skills or work experience to increase their prospects of accessing stable employment.
  • The category ‘severely disadvantaged workers’ includes persons who:
    • have not been in regular paid employment, as defined in (a), for at least 24 months
    • have not been in regular paid employment for at least 12 months, as defined in point (a), and belong to one of the categories referred to in points (b) to (g).

The tax credit can be used, exclusively by means of F24 compensation to be presented through the telematic services made available by the Agenzia delle Entrate (tax code 6897), starting from the tax period following the one in which the eligible expenses are incurred (subject to the fulfilment by the company of the certification obligations).

Companies benefiting from the tax credit are required to draw up and keep:

  • a report illustrating the organisation and content of the training activities carried out
  • any other accounting and administrative documentation suitable to demonstrate the correct application of the benefit, also in relation to the respect of the limits and conditions set by the relevant Community rules
  • the records of the training activities signed by the trainee and teacher or by the trainer outside the company.

Companies intending to take advantage of the benefit are required to send a communication to the Ministry of Economic Development for the sole purpose of acquiring the information necessary to assess the progress, dissemination, and effectiveness of the benefit measures (the model, content, methods, and deadlines for sending the communication will be defined by a specific ministerial decree).