Nuova Sabatini and hyper-depreciation: can they be combined?

Yes: a Nuova Sabatini grant does not, in itself, exclude hyper-depreciation on the same investment. The combination must, however, be calculated correctly. For the same eligible costs, the base to which the tax increase applies must be taken net of the subsidies and grants received. Furthermore, the forms of support cannot cover the same cost portions twice and, taken together, cannot exceed the cost incurred. This is the rule in Article 1, paragraph 431, of Law No. 199 of 30 December 2025.

This is precisely the doubt that can arise in a concrete case: a company purchases an asset, obtains the Nuova Sabatini grant and files the hyper-depreciation communication through the GSE. The investment is the same; does that mean only one incentive can be chosen? No. It means that the cost of the asset, the grant relating to that cost and the effective base for the increase must be distinguished, in compliance with the rules of both measures.

The answer, before the calculations

Paragraph 431 allows hyper-depreciation to be combined with other incentives financed with national or European resources relating to the same costs. Nuova Sabatini provides for a public grant for SMEs' investments in capital goods: its presence therefore does not constitute a general prohibition on accessing hyper-depreciation. The positive answer concerns the possibility of combining the measures, nor the automatic eligibility of any asset or any amount.

To apply both, you must verify separately that the company and the asset meet the requirements of the Nuova Sabatini and those of the hyper-depreciation. You must then allocate the contribution to the costs to which it relates, calculate the uplift on the correct basis and comply with the other limits that may apply to the specific incentive. Paragraph 431 also contains an express exclusion for investments that benefit from the provisions of Article 1, paragraph 446, of Law No. 207 of 30 December 2024: this is a separate check to be carried out on a case-by-case basis.

Sabatini financing and Sabatini contribution are not the same thing

The Nuova Sabatini combines a bank loan or a lease with a ministerial capital grant, calculated according to the rules of the measure. The financing serves to pay for the investment and must be repaid under the relevant contract. The contribution, by contrast, is the public support to be considered when assessing cumulation.

This distinction avoids a common mistake: deducting the entire financing from the hyper-depreciation basis as if it were a non-repayable grant. Paragraph 431 refers to subsidies and contributions received for the same eligible costs. It is therefore necessary to identify how much of the contribution is actually attributable to the asset concerned, especially if the Sabatini application covers multiple assets or expenses with different treatments.

An example: gross cost, contribution and net basis

Let us imagine, purely to illustrate the method, an asset with an eligible cost for hyper-depreciation of 100,000 euros. Suppose the business can also receive a New Sabatini grant of EUR 10,000for that same cost. The basis to be used for the tax uplift is EUR 90,000: the eligible cost less the grant. The uplift rates provided for by the hyper-depreciation rules are then applied to this basis, subject to verification of all the other requirements.

This does not mean that the business has to repay the Sabatini grant. It means that it cannot calculate the tax uplift on the portion of the cost covered by that grant as well. The final tax benefit does not amount to EUR 90,000 and is not obtained simply by adding together the percentages advertised for the two measures: it depends on the applicable uplift, on depreciation or lease payments, and on the business's tax position.

What checks to carry out before confirming cumulation

The first check concerns the asset. The New Sabatini scheme and hyper-depreciation have different requirements, procedures and documents. An investment supported by the Sabatini scheme does not automatically become eligible for the tax uplift. For hyper-depreciation, the type of asset, the technical conditions and the formalities required by the measure must be verified, among other things.

The second concerns the amounts. Invoices, payments, any ancillary costs and grants must be attributed to the individual investment. If the Sabatini grant relates to only part of the project, it is not enough to deduct it indiscriminately from the total or ignore it. A schedule is needed showing which costs are eligible under each measure and which grant affects the basis of the increased deduction. This is also how the absence of double coverage of the same cost shares and the limit of the cost actually incurred are verified.

The third concerns timing and procedures. Application, grant and disbursement under Nuova Sabatini follow their own path; communications and certifications for the hyper-depreciation follow another. If the grant changes in amount, or is awarded or disbursed at a later date, the reconstruction of the cumulation must be updated and assessed with the professionals handling the transaction. The documentation must make it possible to explain why that basis was used, at that time, and which amounts were subsequently confirmed.

What to keep in order to respond to an inspection

To make the calculation verifiable, it is advisable to keep together purchase and payment documents, accounting entries, Nuova Sabatini deeds and communications, the technical documentation required for the hyper-depreciation and a reconciliation schedule for each asset. The schedule should show at least the cost incurred, the cost eligible for the increased deduction, the grants relating to the same costs, the net basis and the criterion by which any grant common to several assets has been apportioned.

For the hyper-depreciation, the Ministry also indicates the sworn technical appraisal and the accounting certification of costs. These are documents with different functions: the appraisal concerns the technical requirements, whereas the accounting certification verifies that the expenses were actually incurred and that they correspond to the accounting records within the scope of the engagement. Neither replaces the overall verification of the conditions for cumulation.

In short, Nuova Sabatini and hyper-depreciation can coexist on the same investment, provided that the asset is eligible under both measures and the cumulation complies with the applicable conditions. The decisive step is simple to state, but must be documented precisely: eligible cost minus grants relating to the same costs equals the base for the uplift. It is the answer to the practical doubt; the cost schedule is what makes it demonstrable.

General information content. For assessments relating to your company, it is necessary to examine the specific case.