New tax credit for research and development in the semiconductor sector – PwC

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11.10.2023 12:14:57
The so-called Omnibus decree (DL no. 104 of 10 August 2023) containing “Urgent provisions to protect users, regarding economic and financial activities and strategic investments” introduced – in line with the objectives indicated in the European Commission communication (COM 2022) 45 final of 8 February 2022, concerning «A chip regulation for Europe» – a new bonus, in the form of a tax credit, for companies investing in research and development activities in the microelectronics and semiconductors, an increasingly strategic sector for our country to be able to compete with other advanced economies.
The regulations in this regard are contained in Article 5 of the aforementioned decree “Tax credit for research and development in microelectronics and Technical Committee for microelectronics” which provides that the tax credit is used in compensation in the F24 model, starting from the subsequent tax period the one in which incurred the eligible costs. For this measure, resources equal to 530 million have been allocated which will be divided as follows: 10 million for 2024, and respectively 130 million for the following years up to 2028, thus covering the costs incurred from the entry into force of the decree until to the period ended 31 December 2027.
It should be noted that there will be no cumulation with the already existing tax credit for R&D, innovation, and design activities, provided for by law 160/2019 and subsequent amendments.
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