Companies that bring back to Italy activities previously carried out outside the European Union have benefited, since 2024, from a 50% exemption of income from IRES and IRAP for six tax periods (Article 6 of Legislative Decree 209/2023), still in force in 2026. Around this lever sit other incentives that changed in 2026: Transition 4.0 and 5.0 has merged into the new hyper-depreciation 2026-2028 (an uplift of up to +180% of cost), while the Mezzogiorno’s ZES Unica has been refinanced for 2026-2028, with €2.3 billion in 2026 alone and extended to Marche and Umbria.
Globalization allowed companies to cut costs and expand markets, but recent crises have exposed its vulnerabilities. The COVID-19 pandemic, supply chain bottlenecks, energy shocks, and geopolitical rivalries have shown that excessive reliance on offshore production can threaten business continuity.
In this new landscape, one of Italy business relocation incentives, reshoring – the transfer of business activities back to Italy – is no longer anecdotal but part of the country’s industrial strategy. Italy has taken a distinctive step: through Article 6 of Legislative Decree No. 209 of 27 December 2023, effective from 1 January 2024, it introduced a tax relief that excludes 50% of profits derived from reshored activities from both corporate income tax (IRES/IRPEF) and the regional production tax (IRAP). Few other EU Member States have opted for such a direct, profit-based incentive.
The legal framework: Article 6, Legislative Decree 209/2023
The provision is not a mere “tax break.” It is a structured regime with strict eligibility criteria and a clear compliance architecture.
Scope and conditions
- Eligible activities: only those relocated from non-EU/EEA jurisdictions. Transfers from within the EU/EEA are explicitly excluded.
- Exclusion of prior presence: the activity must not have been carried out in Italy within the previous 24 months. This avoids opportunistic “round trips.”
- Separate accounting: companies must maintain dedicated accounts able to ring-fence revenues, costs, and assets linked to the reshored activity. This is not a formality: it ensures auditability of the relief and avoids spillovers into unrelated income.
- Benefit: 50% of profits excluded from IRES/IRPEF and IRAP, for six years (the transfer year plus five). Large undertakings may apply for an extension to ten years.
- Clawback (recapture): if the reshored activity is moved abroad again within five years (ten for large undertakings) after the incentive period, all taxes avoided must be repaid with interest.
- EU clearance: under Article 108(3) TFEU, the effectiveness of the measure is subject to prior authorization by the European Commission.
Why Brussels matters
Unlike investment tax credits, which usually fall under the General Block Exemption Regulation (GBER, Reg. 651/2014, as amended in 2023), Italy relocation incentive such as reshoring acts directly on taxable profits. This makes it more intrusive in terms of competition policy. For that reason, the law itself conditions its application on Commission approval.
As of September 2025, the Commission has not yet published a specific State aid decision on the reshoring regime in its SA database. This means companies should consider the benefit as conditional until clearance is granted. For investors, the practical implication is that planning must factor in both national law and EU timing: no aid can be executed without prior approval.
This alignment with EU law also explains the strict design of the regime: separate accounting and clawback rules are the safeguards that make the measure more defensible in Brussels. They demonstrate that Italy is not offering a blanket corporate tax cut, but a targeted, reversible relief tied to documented activities.
Financial impact: why CFOs care
For corporate finance, the appeal is straightforward: this Italy business relocation incentive reduces the effective tax burden on EBIT from reshored units.
Take a conservative case:
- Annual profit from reshored activity: €5 million.
- Excluded from taxation: €2.5 million.
- At standard rates (24% IRES + ~3.9% IRAP), the annual tax saving exceeds €600,000.
- Over six years, cumulative savings can surpass €3.7 million.
This is not an abstract figure: it can fund capital expenditures, energy retrofits, staff reskilling, or cash buffers to stabilize operations during the transition. It transforms the reshoring decision from a cost centre into a financially viable project.
Interaction with other Italian measures
Although the reshoring regime is standalone, it sits within a broader ecosystem:
- ZES Unica (Single SEZ for Southern Italy): a credit on new investments in machinery, plants, and sometimes buildings located in Southern regions. For companies reshoring to the South, this lowers CAPEX while the reshoring relief lowers the tax burden on profits.
- hyper-depreciation 2026-2028 Plan: a credit tied to certified energy savings and digital transformation. It allows reshored units to modernize operations and benefit from additional fiscal support aligned with EU Green Deal goals.
Together, these business incentives in Italy create a layered incentive structure: income-based relief (reshoring) + investment-based relief (ZES and 5.0). The combination is rare in Europe and strategically positioned to attract industrial relocations.
The reshoring incentives compared (2026)
Three fiscal levers, updated by the 2026 Budget Law, can act together on the relocation of an activity. The table summarizes who they are for, the benefit and the duration.
| Incentive | Who it is for | Benefit | Duration |
|---|---|---|---|
| Business reshoring (Art. 6, Legislative Decree 209/2023) | Companies bringing back to Italy activities carried out in non-EU/EEA countries | 50% exemption of income from IRES and IRAP | 6 tax periods (year of transfer + 5) |
| Hyper-depreciation 2026-2028 (ex Transition 4.0/5.0) | Companies investing in 4.0 capital goods and in renewable self-generation | Uplift to deductible cost: +180% up to €2.5M, +100% €2.5–10M, +50% €10–20M | Investments from 1 Jan 2026 to 30 Sept 2028 |
| ZES Unica (Southern Italy) | Companies investing in the South (from 2026 also Marche and Umbria) | Investment tax credit, €2.3bn allocation for 2026 | Refinanced for 2026-2028 |
What an international CFO needs to know
- The Italian reshoring regime excludes 50% of profits from taxation for six years (extendable to ten).
- Eligibility is limited to transfers from non-EU/EEA jurisdictions and requires no prior activity in Italy in the last 24 months.
- Separate accounting is mandatory; without it, benefits are indefensible in audit.
- Clawback applies if the activity is re-delocalized within five or ten years after the incentive period.
- The regime is subject to prior EU Commission authorization; companies should monitor the State aid case (DG COMP).
- Synergies exist with ZES Unica and hyper-depreciation 2026-2028, but EU aid intensity caps must always be respected.
EU State aid compliance: intensity caps and cumulation
In the European Union, every national incentive must pass the test of State aid law. The reshoring relief is unusual because it acts directly on profits, whereas most State aid measures are CAPEX-driven. This difference is crucial.
Under the General Block Exemption Regulation (GBER, Reg. 651/2014, consolidated 2023), Member States can grant aid without prior notification if they respect specific categories and maximum aid intensities. For example, regional investment aid typically ranges from 25% to 50% of eligible costs, depending on company size and location.
By contrast, the reshoring relief excludes 50% of profits from taxation. This is not an “investment aid” in the GBER sense, which is why Article 6 of Decree 209/2023 explicitly requires prior Commission authorization. Until that clearance is granted, companies should consider the incentive conditional.
The practical takeaway:
- ZES Unica and hyper-depreciation 2026-2028 are more straightforward, as they fit within the GBER categories (regional aid, environmental aid, digitalization).
- The reshoring incentive is innovative but requires case-by-case compatibility.
- Cumulation is possible because the bases differ: profits vs. investments. The risk is not double-counting the same cost, but exceeding the overall aid intensity cap.
ZES Unica: geography as a strategic lever
The Single Special Economic Zone (ZES Unica) is not just a tax benefit: it is a policy tool to rebalance Italy’s industrial geography. Covering the entire South – from Sicily and Sardinia to Calabria, Campania, Puglia, Basilicata, Molise, and Abruzzo – it offers tax credits on new tangible assets such as machinery, equipment, and in some cases industrial buildings.
For reshoring projects, location matters. A company that chooses to relocate to Southern Italy can combine the 50% income exclusion with an upfront reduction in CAPEX. For capital-intensive sectors – manufacturing, automotive components, logistics – this dual mechanism can tip the balance of an investment committee.
However, incentives come with obligations. Accessing the ZES credit requires formal application through the Italian Revenue Agency, compliance with eligibility rules, and evidence that the assets are installed and used in the eligible area. It is both an opportunity and a commitment: by choosing the South, companies benefit fiscally but must also integrate into regions with different infrastructure, workforce dynamics, and supply chains.
From 2026, the ZES Unica has been refinanced for the 2026-2028 period, with an allocation of €2.3 billion for 2026 alone, and has been extended to Marche and Umbria. To offset the reduction of the credit rate to 60% recorded in 2025, the 2026 Budget Law introduced an additional 14.6% credit.
From 2026, Transition 5.0 becomes hyper-depreciation: what changes for reshoring
From 2026, the second complementary lever is no longer the Transition 5.0 tax credit but the new hyper-depreciation 2026-2028, introduced by the 2026 Budget Law for investments in 4.0 capital goods and in self-produced energy from renewable sources. Unlike the old mechanism, it is not a credit offset against tax due: it is an uplift to the asset’s tax cost that increases deductible depreciation in the tax return.
The uplift reaches +180% of the cost up to €2.5 million, +100% between €2.5 and €10 million, and +50% between €10 and €20 million; with corporate income tax (IRES) at 24%, the effective benefit reaches 43.2% of the investment. Access runs through the platform of the Energy Services Manager (GSE), with the filings and certifications required on eligible investments.
A company relocating today rarely just rebuilds in Italy the line it had abroad: the opportunity — and, in a sense, the implicit condition — is to modernize the plant. Founders and investors weighing the move will find the routes in the Italy Startup Visa and the Italy Golden Visa.
Execution discipline: how to stay audit-ready
Having incentives on paper is not enough. What distinguishes successful reshoring projects is execution discipline.
Key elements include:
- Documenting the non-EU/EEA origin of the activity, with contractual and operational proof.
- Demonstrating discontinuity with any presence in Italy over the past 24 months.
- Implementing separate accounting systems that can withstand both tax audits and EU State aid transparency requirements.
- Planning for recapture: group policies should commit to maintaining the activity in Italy well beyond the incentive horizon, to avoid clawback risk.
- Integrating multiple incentives: mapping ex ante whether ZES (territorial) or hyper-depreciation 2026-2028 (functional) apply, and ensuring aid intensity caps are respected.
These are not “best practices” but compliance necessities. The burden of proof lies with the taxpayer, and failure to document any of these steps can result in loss of benefit or repayment orders.
Conclusion: a strategic, not tactical, choice
Italy’s reshoring incentive is more than a tax relief: it is a policy signal. By halving taxable profits, the government makes relocation financially attractive. By imposing strict conditions – separate accounts, recapture, EU clearance – it ensures that only genuine, stable relocations qualify. And by linking the regime to complementary tools like ZES and hyper-depreciation 2026-2028, it aligns reshoring with territorial development and green industrial policy.
For international investors, the message is clear: returning to Italy is not just about nostalgia or branding. It is a structural decision, backed by measurable fiscal advantages, but also bound by compliance obligations that require careful planning.
Companies evaluating a reshoring project should not simply ask “what is the tax saving?” but rather “how do these incentives fit into a 10-year industrial strategy?”
- Italian Revenue Agency — Activities transferred to Italy and impatriate workers (Legislative Decree 209/2023).
- Ministry of Enterprise (MIMIT) — New hyper-depreciation (ex Transition 5.0), 2026-2028.
- Italian Ministry of Economy and Finance — Key measures of the 2026 Budget Law.
- Italian Revenue Agency — Tax reliefs for those transferring residence or business to Italy.
- ZES Unica — 2026 investment tax credit: allocation and territorial scope.
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FAQ
In 2026 reshoring rests on three levers. A 50% exemption of income from corporate tax (IRES) and IRAP for activities brought back to Italy from non-EU countries (Article 6 of Legislative Decree 209/2023), for six tax periods. The new hyper-depreciation 2026-2028 for investments in 4.0 capital goods and renewable self-generation. And the Mezzogiorno’s ZES Unica, refinanced for the 2026-2028 period.
Article 6 of Legislative Decree 209/2023 provides that income from business or self-employment activities transferred to Italy from a non-EU or non-EEA country does not contribute, for 50% of its amount, to the IRES and IRAP tax base. The benefit applies for six tax periods — the year of transfer and the following five — and is still in force in 2026. A recapture clause applies if the activity is relocated abroad again.
From 1 January 2026 the Transition 4.0 and 5.0 tax credit is replaced by the new hyper-depreciation 2026-2028, introduced by the 2026 Budget Law. It is no longer a credit offset in the F24 form but an uplift to the asset’s tax cost: +180% up to €2.5 million, +100% between €2.5 and €10 million, +50% between €10 and €20 million. With IRES at 24%, the effective benefit reaches 43.2% of the investment.
The ZES Unica is the Special Economic Zone unifying Southern Italy, granting an investment tax credit. With the 2026 Budget Law it has been refinanced for the 2026-2028 period, with €2.3 billion allocated for 2026 alone, and extended to Marche and Umbria. An additional 14.6% credit offsets the rate reduction recorded in 2025.
In principle the three measures rest on different bases — income from the relocated activity, investment in capital goods and investment located in the South — and can work together. Cumulation, however, must be checked case by case against EU State aid rules and each measure’s caps, to avoid double benefits on the same cost. This is where a tax due-diligence pays off before deciding on location.
Article 6 covers business activities and self-employment carried out in associated form that were performed in a non-EU or non-EEA country and are transferred to Italy. It is a binary origin filter: if the activity comes from another EU Member State, the relief does not apply. The benefit is granted provided the activity was not already carried out in Italy in the periods before the transfer.
