NEW HIRINGS WITH MAXI-DEDUCTION BONUS: THE CLARIFICATIONS OF THE NATIONAL TAX AUTHORITY
With circular no. 1/E of 20 January 2025, the National Tax Authority provides operational instructions for the "new hires bonus with maxi-deduction" introduced by Article 4, paragraph 6 of Legislative Decree. 216/2023 and extended for the tax periods 2025, 2026 and 2027 by the art. 1 paragraphs 399-340 of the Budget Law 2025.
The measure allows for the increase of labor costs eligible for deduction for new permanent hires, subject to specific criteria.
Regarding the determination of the increase in labor costs eligible for deduction, it is generally represented by a 20% increase (resulting in a total tax deduction of 120%), which rises by an additional 10% for the hiring of individuals deserving special protection.
The beneficiaries of this incentive are identified, under certain conditions, mainly as (a) business income earners, (b) those practicing arts and professions, including in associated forms, (c) individuals residing in Italy who produce self-employment income in Italy through a fixed base, (d) individuals not residing in Italy who produce business income in Italy through a permanent establishment.
To benefit from the bonus, it is necessary that, at the end of the facilitated tax period, the aforementioned subjects who hire new permanent staff register both an "overall employment increase" (the increase in permanent employees must be associated with an increase in the total number of employees, including temporary ones) and a "stable employment increase" (the number of permanent employees must have increased compared to the average number of permanent employees employed in the previous tax period). Both increases must be considered net of any employment reductions in controlled or affiliated companies or attributable, even indirectly, to the same subject.
