Hyper-Depreciation 2026: Software Is Eligible for Tax Relief Again

There is a piece of news that many business owners had been waiting for: software is once again eligible for tax relief. After a 2025 in which intangible assets had effectively been excluded from the Transition 4.0 incentives, the 2026 Budget Law (Law no. 199 of 30 December 2025) has reintroduced the hyper-depreciation scheme, explicitly including software, systems, platforms and digital applications among the assets that can benefit from the tax uplift.

For Italian SMEs that postponed digitalisation investments while waiting for more favourable conditions, a real window of opportunity is now opening. Companies considering the adoption of an ERP system, a WMS for warehouse management or a MES platform for production now have one more reason to move forward: a tax deduction that can reach 100% of the invested value.

From Tax Credit to Hyper-Depreciation: What Really Changes

The 2026 Budget Law marks a paradigm shift in the incentives for technology investments. The Transition 4.0 and 5.0 tax credits that have shaped recent years give way to the return of hyper-depreciation. These are two profoundly different mechanisms, and it is important to understand them before planning any investment.

With the tax credit, a company accrued a credit to be offset through the F24 form, obtaining a relatively quick and direct benefit. Hyper-depreciation works differently: it allows the tax-recognised cost of the purchased asset to be increased, thereby raising the deductible depreciation charges in the years following the investment. The result is a reduction of the IRES or IRPEF taxable base that is spread over the useful life of the asset.

This difference has significant practical implications. The benefit is not immediate but materialises progressively, year after year, through lower taxes to be paid. For a company with structured tax planning, this can still represent an important advantage: the certainty of a steady tax saving over several financial years, which improves cash flow predictability and the financial sustainability of technology investments.

It should be stressed that hyper-depreciation operates purely on the tax side. In the accounts, the asset continues to be recorded at its actual purchase cost. The uplift comes into play only in the tax calculation, creating an off-book deduction that reduces the tax burden without altering the statutory financial statements.

Software and Intangible Assets: Rates and Calculating the Tax Advantage

For the intangible assets listed in Annex V to the 2026 Budget Law, the uplift provided for is 100%. This means that the cost of the software, for the sole purpose of calculating tax depreciation, is doubled. The list of eligible assets includes software, systems and system integration, platforms and applications linked to investments in tangible Industry 4.0 assets, as well as software and digital services for the use of cloud computing services and for cybersecurity.

In practical terms, the relief covers advanced ERP systems, WMS solutions for warehouse management, MES platforms for production control, Business Intelligence and analytics software, Supply Chain Management solutions and integrated Customer Relationship Management systems. The fundamental requirement is that this software be interconnected with the company's production management system or with the supply network, in line with the Industry 4.0 paradigm.

To grasp the tax advantage concretely, consider a realistic example. A company decides to invest 30,000 euros in an ERP management software with integrated modules for production and warehouse. With the 100% uplift, the tax depreciation base becomes 60,000 euros instead of 30,000. This generates an additional deduction of 30,000 euros compared with ordinary depreciation. Applying the 24% IRES rate, the total tax saving amounts to 7,200 euros.

This benefit is spread over the software's depreciation period, which typically runs from three to five years. In a scenario with five-year depreciation, the company obtains a saving of roughly 1,440 euros per year in lower IRES. It is not a direct refund, but a structural reduction of the tax burden that improves the return on the investment and shortens its payback time.

It is worth briefly noting that for the tangible assets included in Annex IV, such as interconnected machinery, robots and automation systems, the uplift rates are even higher: they reach up to 180% for investments up to 2.5 million euros, with decreasing percentages for higher tiers. However, for most SMEs whose main need is to digitalise their processes through management software, it is the 100% uplift on intangible assets that represents the most relevant and accessible opportunity.

Requirements, Constraints and Deadlines to Observe

Access to hyper-depreciation is not automatic and requires compliance with specific requirements, both technical and procedural. The first and most important is interconnection: the software must be effectively linked to the company's production management system or to the supply network. It is not enough to buy a management system and install it; there must be an exchange of information with other machines, with logistics systems or with the supply chain, following Industry 4.0 logic.

The 2026 Budget Law also introduces a significant geographical constraint: eligible assets must be produced in a Member State of the European Union or in countries belonging to the European Economic Area (Iceland, Liechtenstein and Norway). For software, this means having to verify that the producer is based in these territories, an aspect to be considered carefully when selecting a supplier.

On the documentation side, a sworn appraisal drawn up by an engineer or industrial expert registered with the professional register is required, or a certificate of conformity issued by an accredited certification body, attesting to the technical characteristics of the asset and its interconnection. For assets costing less than 300,000 euros, a substitute declaration by the legal representative is also permitted.

The time window for making the investments runs from 1 January 2026 to 30 September 2028. Access to the benefit takes place through an IT platform managed by the GSE, with a process structured around three mandatory communications: an advance communication indicating the amount of the planned investments, a confirmation communication attesting to the payment of at least 20% of the cost, and a completion communication to be submitted by 15 November 2028.

The MIMIT has already forwarded to the Ministry of Economy and Finance the draft interministerial decree setting out the implementing rules. Once published in the Official Gazette, companies will have a complete framework to plan their investments in full regulatory certainty.

The Right Time to Invest in Digitalisation

The return of software among the eligible assets, after a year of exclusion, is a clear signal: the digitalisation of SMEs remains a strategic priority for the country's economic system. For companies that have postponed digital transformation projects, the 2026-2028 three-year period offers favourable tax conditions well worth seizing.

The complexity of the technical and procedural requirements, however, calls for a structured approach. It is not simply a matter of buying software and reporting the investment: a preliminary assessment is needed to verify the eligibility of the asset, the feasibility of the interconnection, the supplier's compliance with the geographical requirements and the correct preparation of the technical documentation.

A126 Corporate Advisors supports SMEs along this path, from the initial assessment of technical feasibility through to the management of the obligations required by the regulation. Our approach combines technological expertise and knowledge of business processes, to turn a tax incentive into a real competitive advantage. Contact us for a preliminary consultation and discover how the 2026 hyper-depreciation scheme can accelerate the digitalisation of your business.

A126 Corporate Advisors – Technology at the service of business strategy.