Italy Eco-bonus 110%, credit transfer, invoice discount

The Relaunch Decree (Law 77/2020) provided for an immediate discount on the invoice and the transfer of credit not only for the subsidized interventions with the 110% super bonus, but also for those falling within the traditional eco-bonus, the renovation bonus and the facade bonus .

From renovations to the 110% superbonus, let's see which deductions can be sold and the procedure to follow.

December 22, 2020 technical contribution by Tatiana Oneta, article by Luca Cartapatti

The relaunch decree introduced the possibility of transferring the deductions that give the right to the 110% superbonus, extending this possibility also to building renovation works, the eco-bonus and the seismabonus that do not fall within the 110% deduction, obtaining the discount directly on the invoice from the supplier or receiving reimbursement of the amount spent also from banks or financial institutions.

What deductions you can give

If, from January 1st 2020 to December 31st 2021, you incur expenses for interventions:

  • give the right to a 110% Superbonus to be divided over 5 years (for expenses incurred from 1 July 2021);
  • of building renovation deductible in 10 years;
  • energy redevelopment that entitles the holder to the eco-bonus or the seismabonus to be divided over 10 years;
  • recovery or restoration of building facades (facades bonus) to be divided over 10 years;
  • installation of photovoltaic systems;
  • installation of charging stations for electric vehicles;

You can assign your deduction to the suppliers of the goods or services necessary for carrying out the intervention, to third parties (private entities such as other condominiums, companies, entities or professionals) or to credit institutions or financial intermediaries.

Instead of the deduction, you can choose to obtain a discount of the same amount on the invoice applied directly by the supplier equal to the maximum amount to be paid. Therefore, if you do a renovation that costs 10,000, which entitles you to a 50% deduction, you will only pay 5,000 euros to the supplier. If the same expense entitles you to a 110% deduction, you will not pay anything but you will not recover the 1,000 euros of additional deduction that you would obtain by indicating it in your tax return.

The supplier, on the other hand, can use the deduction obtained in the form of a tax credit or transfer it in turn to financial intermediaries or credit institutions. In particular, if a superbonus tax credit is granted to him, he will also have that 10% available that he did not recognize as a discount on the invoice. For example, for an expense of 10,000 euros that he has totally discounted, he obtains a tax credit of 11,000 to be used over 5 years because the original deduction provides for this recovery time.

Alternatively, you can choose to "transform" the deduction into a tax credit and transfer it directly to other subjects, who will be able to use it to offset the taxes due with the same number of installments that the original deduction provides or transfer it in turn. In this case, you assign the exact amount of the deduction, therefore in the case of the superbonus with a 110% deduction, for an expense of 10,000 euros you assign a credit of 11,000 euros.

The transfer option can be made in relation to each state of progress of the works which, with reference to the interventions that give the right to the Superbonus, cannot be more than two for each overall intervention. Furthermore, the first stage of progress must refer to at least 30% and the second to at least 60% of the intervention itself.

For the expenses incurred in 2020 and 2021, it is also possible to exercise the option of assigning the credit even only for some residual installments. For example, for an expense incurred in 2020 you can choose to enter the first two installments in the return and assign the credit corresponding to the other three. In any case, it is not possible to recover the tax credit not used during the year by requesting a refund or inserting it in subsequent tax returns.

If more people are entitled to the deduction for the expenses incurred, they can each decide in total autonomy on the use of the same. Therefore, even in the case of condominium interventions, it does not necessarily have to be the condominium that opts for the transfer of credit or for the discount on the invoice, each condominium can decide for himself.

The legislation in this regard is particularly complex, especially if the credit transfer concerns the 110% Superbonus, to learn more about this aspect also consult our FAQ.

How to assign the deduction

The transfer must be communicated by the beneficiary of the deduction directly electronically via the website of the Revenue Agency or by contacting CAF or qualified professionals (accountants, labor consultants ...). In the case of condominium works for which everyone has opted for the sale, it is the administrator who takes care of the communication. If, on the other hand, the individual condominium opts for the sale, he must notify the administrator.

To communicate the credit transfer you must connect to the Revenue Agency website and log in using your credentials or Spid. Once in your desk, from the menu on the left you have to select "services for" and then "communicate". At this point, from the list that appears, select "transfer / discount option communication" to access the form to be completed electronically and the relative compilation instructions. Remember that the communication must be made by March 16 of the year following the one in which the expenses that give the right to the deduction transferred were incurred.

Within 5 days of sending the communication, a receipt of acceptance or rejection of the request is issued. By day five of the month following the one in which it was sent, you can cancel the communication presented or send an entirely replacement one.

Only for the transfer of the 110% superbonus, in addition to the obligations provided for by the specific legislation and the communication of the credit transfer, it is also necessary to obtain the compliance visa from a CAF or from a professional who certifies the existence of the conditions that give the right to deduction. In this case, it also reminds you that the communication for the assignment of the credit must take place after 5 working days following the release by ENEA of the receipt of the certification of the work carried out.

Government checks

If it is ascertained that the taxpayer is not due, even partially, of the deduction, the recovery of the relative amount will be increased by interest and a penalty. In fact, if during the checks of the Revenue Agency or ENEA it is found that the taxpayer was not entitled to the deduction, whoever obtained the tax credit in good faith does not lose the right to use it.

If the competition in violation is ascertained, however, they will both be jointly and severally liable towards the Italian tax authorities.

Finally, if the undue use, even partial, of the credit by the supplier (or whoever obtained it) is ascertained, the recovery of the relative amount will take place against him, plus interest and penalty.


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