Il decreto legge 19 maggio 2020, n. 34 in corso di conversione (di seguito, “decreto Rilancio”) reca misure urgenti in materia di salute, sostegno al lavoro e all’economia, nonché di politiche sociali, connesse all’emergenza epidemiologica da Covid-19.
Con gli articoli 120 e 125 del menzionato decreto Rilancio, sono stati introdotti, rispettivamente, i seguenti crediti d’imposta:
- per gli interventi e gli investimenti necessari per far rispettare le prescrizioni sanitarie e le misure di contenimento contro la diffusione del virus Covid-19 (articolo 120 del decreto Rilancio, di seguito, “credito d’imposta per l’adeguamento degli ambienti di lavoro”);
- per la sanificazione degli ambienti e degli strumenti utilizzati, nonché per l’acquisto di dispositivi di protezione individuale e di altri dispositivi atti a garantire la salute dei lavoratori e degli utenti (articolo 125 del decreto Rilancio, di seguito “Credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione”).
Con la presente circolare si forniscono i primi chiarimenti di carattere interpretativo e di indirizzo operativo agli uffici dell’Agenzia delle entrate.
Inoltre qui potete scaricare un aggiornamento con le tempistiche che è necessario seguire per una corretta gestione dell’utilizzo diretto da parte del beneficiario ovvero per la cessione a terzi (e il successivo utilizzo da parte del cessionario).
1 Il credito di imposta per l’adeguamento degli ambienti di lavoro (articolo 120)
Il credito di imposta per l’adeguamento degli ambienti di lavoro è riconosciuto a favore di un’ampia platea di soggetti (tipicamente gli operatori con attività aperte al pubblico), a fronte delle spese sostenute per gli interventi necessari al rispetto delle prescrizioni sanitarie e delle misure di contenimento contro la diffusione del virus. La misura, come detto, è stata introdotta dall’articolo 120 del decreto legge n. 34 suddetto (d’ora in poi, “articolo 120“).
1.1 Ambito soggettivo di applicazione
Il credito d’imposta per l’adeguamento degli ambienti di lavoro, ai sensi del comma 1 dell’articolo 120, è riconosciuto «ai soggetti esercenti attività d’impresa, arte o professione in luoghi aperti al pubblico indicati nell’allegato 1, alle associazioni, alle fondazioni e agli altri enti privati, compresi gli enti del Terzo settore».
Al riguardo, nella relazione illustrativa si precisa che il credito d’imposta per l’adeguamento degli ambienti di lavoro è previsto in riferimento alle spese necessarie alla riapertura in sicurezza delle attività e che la platea dei soggetti possibili beneficiari è costituita dagli operatori con attività aperte al pubblico, tipicamente bar, ristoranti, alberghi, teatri e cinema. In particolare, deve trattarsi di:
a) attività di impresa, arte o professione esercitata in luogo aperto al pubblico (ovvero in luogo al quale il pubblico possa liberamente accedere, senza limite o nei limiti della capienza, ma solo in certi momenti o alle condizioni poste da chi esercita un diritto sul luogo) ricompresa nell’elenco di cui all’allegato 1 (vedi infra);
b) associazioni, fondazioni e altri enti privati1 , compresi gli enti del Terzo settore2 .
Con riferimento alla lettera a), si tratta dei seguenti soggetti, purché riconducibili all’elenco di cui all’allegato 1:
- degli imprenditori individuali e delle società in nome collettivo e in accomandita semplice che producono reddito d’impresa indipendentemente dal regime contabile adottato;
- degli enti e società indicati nell’articolo 73, comma 1, lettere a) e b), del TUIR;
- delle stabili organizzazioni di soggetti non residenti di cui alla lettera d), del comma 1, dell’articolo 73 del TUIR;
- delle persone fisiche e delle associazioni di cui all’articolo 5, comma 3, lettera c), del TUIR che esercitano arti e professioni, producendo reddito di lavoro autonomo ai sensi dell’articolo 53 del TUIR.
Conseguentemente, non rientrano tra i soggetti inclusi nella lettera a) in parola coloro che, svolgendo attività commerciali non esercitate abitualmente o attività di lavoro autonomo non esercitate abitualmente, ritraggono dalle stesse redditi diversi, ai sensi dell’articolo 67, comma 1, lettere i) e l), del TUIR.
Non essendo prevista alcuna distinzione tra le attività in funzione del regime fiscale adottato, devono ritenersi inclusi nell’ambito soggettivo:
- i soggetti in regime forfetario di cui all’articolo 1, commi 54 e seguenti della legge n. 190 del 23 dicembre 2014;
- i soggetti in regime di vantaggio di cui all’articolo 27, commi 1 e 2 del decreto legge n. 98 del 6 luglio 2011;
- gli imprenditori e le imprese agricole, sia che determinino per regime naturale il reddito su base catastale, sia quelle che producono reddito d’impresa.
I soggetti appena menzionati devono svolgere effettivamente una delle attività ammissibili, le quali sono individuate nell’allegato 1 in parola sulla base della relativa classificazione ATECO 2007, come da tabella di seguito riportata.
| codice ATECO 2007 |
Denominazione |
| 551000 | Alberghi |
| 552010 | villaggi turistici |
| 552020 | ostelli della gioventù |
| 552030 | rifugi di montagna |
| 552040 | colonie marine e montane |
| 552051 | affittacamere per brevi soggiorni, case ed appartamenti per vacanze, bed and breakfast, residence |
| 552052 | attività di alloggio connesse alle aziende agricole |
| 553000 | aree di campeggio e aree attrezzate per camper e roulotte |
| 559010 | gestione di vagoni letto |
| 559020 | alloggi per studenti e lavoratori con servizi accessori di tipo alberghiero |
| 561011 | ristorazione con somministrazione |
| 561012 | attività di ristorazione connesse alle aziende agricole |
| 561020 | ristorazione senza somministrazione con preparazione di cibi da asporto |
| 561030 | gelaterie e pasticcerie |
| 561041 | gelaterie e pasticcerie ambulanti |
| 561042 | ristorazione ambulante |
| 561050 | ristorazione su treni e navi |
| 562100 | catering per eventi, banqueting |
| 562910 | Mense |
| 562920 | catering continuativo su base contrattuale |
| 563000 | bar e altri esercizi simili senza cucina |
| 591400 | attività di proiezione cinematografica |
| 791100 | attività delle agenzie di viaggio |
| 791200 | attività dei tour operator |
| 799011 | servizi di biglietteria per eventi teatrali, sportivi ed altri eventi ricreativi e d’intrattenimento |
| 799019 | altri servizi di prenotazione e altre attività di assistenza turistica non svolte dalle agenzie di viaggio NCA |
| 799020 | attività di guide e degli accompagnatori turistici |
| 823000 | organizzazione di convegni e fiere |
| 900101 | attività nel campo della recitazione |
| 900109 | altre rappresentazioni artistiche |
| 900201 | noleggio con operatore di strutture ed attrezzature per manifestazioni e spettacoli |
| 900202 | attività nel campo della regia |
| 900209 | altre attività di supporto alle rappresentazioni artistiche |
| 900400 | gestione di teatri, sale da concerto e altre strutture artistiche |
| 910100 | attività di biblioteche ed archivi |
| 910200 | attività di musei |
| 910300 | gestione di luoghi e monumenti storici e attrazioni simili |
| 910400 | attività degli orti botanici, dei giardini zoologici e delle riserve naturali |
| 932100 | parchi di divertimento e parchi tematici |
| 932920 | gestione di stabilimenti balneari: marittimi, lacuali e fluviali |
| 960420 | stabilimenti termali |
Per quanto concerne le associazioni, le fondazioni e gli altri enti privati, compresi gli enti del Terzo settore, indicati sub b), come precisato nella circolare n. 9/E del 13 aprile 2020, si ritiene che il legislatore abbia inteso estendere il beneficio in questione a tutti gli enti diversi da quelli che esercitano, in via prevalente o esclusiva, un’attività in regime di impresa in base ai criteri stabiliti dall’articolo 55 del TUIR.
Stante il tenore letterale della norma, tali soggetti sono inclusi tra i beneficiari dell’agevolazione, anche nell’ipotesi in cui non svolgano una delle attività individuate all’allegato 1 aperte al pubblico.
1.2 Ambito oggettivo di applicazione
Le spese in relazione alle quali spetta il credito d’imposta per l’adeguamento degli ambienti di lavoro sono suddivise in due gruppi: quello degli interventi agevolabili e quello degli investimenti agevolabili:
1) gli interventi agevolabili sono quelli necessari al rispetto delle prescrizioni sanitarie e delle misure finalizzate al contenimento della diffusione del virus SARS-Co V-2, tra cui rientrano espressamente:
a) quelli edilizi necessari per il rifacimento di spogliatoi e mense, per la realizzazione di spazi medici, di ingressi e spazi comuni, nonché per l’acquisto di arredi di sicurezza. Sono ricomprese in tale insieme gli interventi edilizi funzionali alla riapertura o alla ripresa dell’attività, fermo restando il rispetto della disciplina urbanistica;
b) gli interventi per l’acquisto di arredi finalizzati a garantire la riapertura delle attività commerciali in sicurezza (cosiddetti “arredi di sicurezza”).
2) gli investimenti agevolabili sono quelli connessi ad attività innovative, tra cui sono ricompresi quelli relativi allo sviluppo o l’acquisto di strumenti e tecnologie necessarie allo svolgimento dell’attività lavorativa e per l’acquisto di apparecchiature per il controllo della temperatura (c.d. termoscanner) dei dipendenti e degli utenti. In merito alle nozioni di “innovazione” o “sviluppo”, occorre fare riferimento agli investimenti che permettono di acquisire strumenti o tecnologie che possono garantire lo svolgimento in sicurezza dell’attività lavorativa da chiunque prestata (ad esempio: titolari, soci, dipendenti, collaboratori), siano essi sviluppati internamente o acquisiti esternamente. Ad esempio, rientrano nell’agevolazione i programmi software, i sistemi di videoconferenza, quelli per la sicurezza della connessione, nonché gli investimenti necessari per consentire lo svolgimento dell’attività lavorativa in smart working.
Nel rispetto della ratio legis, inoltre, è necessario che le tipologie di interventi agevolabili di cui al punto 1 siano stati prescritti da disposizioni normative o previsti dalle linee guida per le riaperture delle attività elaborate da amministrazioni centrali, enti territoriali e locali, associazioni di categoria e ordini professionali.
1.3 Modalità e termini di utilizzo
L’ammontare del credito d’imposta in parola corrisponde al 60 per cento delle spese ammissibili sostenute nel 2020 per un massimo di 80.000 euro. Tale limite massimo è riferito all’importo delle spese ammissibili e, dunque, l’ammontare del credito non può eccedere il limite di 48.000 euro. Pertanto, nel caso in cui dette spese siano superiori a tale ultimo importo, il credito spettante sarà sempre pari al limite massimo consentito di 48.000 euro.
Poiché, inoltre, la disposizione fa riferimento alle spese sostenute nel 2020, si ritiene che l’agevolazione spetti anche nel caso in cui il sostenimento sia avvenuto, nel corso dell’anno, prima del 19 maggio 2020, data di entrata in vigore del decreto legge n. 34 istitutivo del credito d’imposta per l’adeguamento degli ambienti di lavoro.
Considerato che nel comma 1 viene utilizzata la locuzione «spese sostenute nel 2020», ai fini dell’imputazione delle spese stesse occorre fare riferimento:
– per gli esercenti arti e professioni e per gli enti non commerciali (nonché per le imprese individuali e le società di persone in regime di contabilità semplificata), al criterio di cassa e, quindi, alla data dell’effettivo pagamento, indipendentemente dalla data di avvio degli interventi e degli investimenti cui i pagamenti si riferiscono. Ad esempio, un intervento ammissibile iniziato a giugno 2020, con pagamenti effettuati sia nel 2020 che nel 2021, consentirà la fruizione del credito d’imposta solo con riferimento ai pagamenti effettuati nel 2020. Per i soggetti in regime di contabilità semplificata che hanno optato per l’applicazione del criterio di cui al comma 5 dell’articolo 18 del decreto del Presidente della Repubblica 29 settembre 1973, n. 600, il pagamento si intenderà effettuato alla data di registrazione del documento contabile;
– per le imprese individuali, per le società, per gli enti commerciali e per gli enti non commerciali in regime di contabilità ordinaria, al criterio di competenza e, quindi, alle spese da imputare al periodo di imposta in corso al 31 dicembre 2020, indipendentemente dalla data di avvio degli interventi cui le spese si riferiscono e indipendentemente dalla data dei pagamenti.
Il calcolo del credito spettante andrà effettuato sulla spesa agevolabile al netto dell’Iva (i.e. sull’imponibile), laddove dovuta. Al riguardo, come chiarito con la circolare n. 34/E del 2016, «il valore degli investimenti realizzati in ciascun periodo agevolato deve essere determinato secondo i criteri ordinari per l’individuazione del costo dei beni rilevante ai fini fiscali previsti dall’articolo 110, comma 1, lettere a) e b), del TUIR, indipendentemente dalle modalità (ordinarie, forfetarie, sostitutive) di determinazione del reddito da parte del contribuente». Pertanto, ai sensi del menzionato articolo 110 del TUIR, l’IVA indetraibile va inclusa nel costo fiscale dei beni cui commisurare il credito d’imposta qui in esame, come avviene per gli oneri accessori capitalizzabili all’investimento principale.
1.4 Opzioni di utilizzo del credito d’imposta
Il credito d’imposta per l’adeguamento degli ambienti di lavoro è utilizzabile (in base al combinato disposto dell’articolo 120, comma 2, del decreto Rilancio con l’articolo 122, comma 2, lettera c), del medesimo decreto):
- esclusivamente in compensazione, ai sensi dell’articolo 17 del decreto legislativo 9 luglio 1997, n. 241 (modello F24); o, in alternativa
- entro il 31 dicembre 2021, può essere ceduto, anche parzialmente, ad altri soggetti, ivi compresi istituti di credito e altri intermediari finanziari, con facoltà di successiva cessione del credito.
In proposito, si precisa che sia l’utilizzo del credito in compensazione tramite modello F24, sia la cessione a soggetti terzi possono avvenire solo successivamente al sostenimento delle spese agevolabili. La norma, inoltre, prevede che il credito potrà essere utilizzato in compensazione da parte del beneficiario ovvero da parte dei cessionari dello stesso solo a decorrere dal 1° gennaio 2021 e non oltre il 31 dicembre 2021; pertanto, eventuali crediti residui al 31 dicembre 2021 non potranno essere utilizzati negli anni successivi, né ulteriormente ceduti oppure richiesti a rimborso.
Al fine di consentire l’utilizzo in compensazione del credito d’imposta per l’adeguamento degli ambienti di lavoro, tramite modello F24 da presentare esclusivamente attraverso i servizi telematici messi a disposizione dall’Agenzia delle entrate, con successiva risoluzione sarà istituito un apposito codice tributo e saranno impartite le istruzioni per la compilazione del modello F24.
A tal riguardo, non si applicano i limiti alle compensazioni stabiliti dall’articolo 1, comma 53, della legge 24 dicembre 2007, n. 244 (crediti d’imposta da indicare nel quadro RU della dichiarazione dei redditi), e di cui all’articolo 34 della legge 23 dicembre 2000, n. 388 (crediti compensati mediante modello F24).
Il credito spettante e i corrispondenti utilizzi andranno indicati nel quadro RU della dichiarazione dei redditi relativa al periodo d’imposta in corso al 31 dicembre 2020, specificando sia la quota compensata tramite modello F24 sia la quota ceduta.
2 Il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione (articolo 125)
L’articolo 125 del decreto Rilancio, al fine di favorire l’adozione di misure dirette a contenere e contrastare la diffusione dell’epidemia, prevede l’assegnazione di un credito d’imposta in favore di taluni soggetti beneficiari, nella misura del 60 per cento delle spese per la sanificazione degli ambienti e degli strumenti utilizzati e per l’acquisto di dispositivi di protezione individuale e di altri dispositivi atti a garantire la salute dei lavoratori e degli utenti.
L’articolo in commento sostituisce il credito d’imposta già previsto dall’articolo 64 del decreto-legge 17 marzo 2020, n. 18, convertito dalla legge 24 aprile 2020, n. 27, per le spese di sanificazione degli ambienti di lavoro e dall’articolo 30 del decreto-legge 8 aprile 2020, n. 23 per l’acquisto di dispositivi di protezione nei luoghi di lavoro.
In particolare, l’articolo 125 del decreto Rilancio:
- abroga, al comma 5, le sopracitate disposizioni normative in argomento (l’articolo 64 del decreto-legge 17 marzo 2020, n. 18, convertito dalla legge 24 aprile 2020, n. 27, e l’articolo 30 del decreto-legge 8 aprile 2020, n. 23) e, al contempo,
- estende la platea dei soggetti beneficiari (agli enti non commerciali, compresi gli enti del terzo settore e gli enti religiosi civilmente riconosciuti),
- estende le spese agevolabili (includendo dispositivi e strumenti quali termometri, termoscanner, tappeti e vaschette decontaminanti e igienizzanti, conformi ai requisiti essenziali di sicurezza previsti dalla normativa europea, comprese le relative eventuali spese di installazione),
- aumenta la misura del beneficio individuale (il credito d’imposta passa dal 50 per cento al 60 per cento e il limite massimo fruibile da 20.000 euro a 60.000 euro).
2.1 Ambito soggettivo di applicazione
Il comma 1 dell’articolo 125 stabilisce che la disposizione in esame trova applicazione nei riguardi di «soggetti esercenti attività d’impresa, arti e professioni, […] enti non commerciali, compresi gli enti del Terzo settore e gli enti religiosi civilmente riconosciuti».
L’ambito soggettivo, pertanto, è circoscritto ai seguenti soggetti:
- imprenditori individuali e società in nome collettivo e in accomandita semplice che producono reddito d’impresa indipendentemente dal regime contabile adottato;
- enti e società indicati nell’articolo 73, comma 1, lettere a) e b), del TUIR;
- stabili organizzazioni di soggetti non residenti di cui alla lettera d), del comma 1, dell’articolo 73 del TUIR;
- persone fisiche e associazioni di cui all’articolo 5, comma 3, lettera c), del TUIR che esercitano arti e professioni, producendo reddito di lavoro autonomo ai sensi dell’articolo 53 del TUIR.
- enti non commerciali, compresi gli enti del Terzo settore;
- enti religiosi civilmente riconosciuti.
La norma non prevede alcuna distinzione in ordine al regime fiscale adottabile dai soggetti beneficiari, pertanto rientrano nell’ambito soggettivo:
- i soggetti in regime forfetario di cui all’articolo 1, commi 54 e seguenti della legge n. 190 del 2014;
- i soggetti in regime di vantaggio di cui all’articolo 27, commi 1 e 2 del decreto legge n. 98 del 6 luglio 2011;
- gli imprenditori e le imprese agricole, sia quelle che determinano per regime naturale il reddito su base catastale, sia quelle che producono reddito d’impresa.
Non sono inclusi tra i soggetti che possono fruire del credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione, coloro che svolgono attività commerciali non esercitate abitualmente o attività di lavoro autonomo non esercitate abitualmente, producendo conseguentemente redditi diversi, ai sensi dell’articolo 67, comma 1, lettere i) e l), del TUIR.
Per quanto concerne gli «enti non commerciali, compresi gli enti del Terzo settore e gli enti religiosi civilmente riconosciuti», in assenza di una espressa limitazione della concessione dell’agevolazione in esame alla sola attività commerciale, considerata altresì l’inclusione degli enti non commerciali, degli enti del terzo settore e degli enti religiosi civilmente riconosciuti tra i soggetti beneficiari nella norma in commento, si ritiene che la volontà del legislatore sia quella di incentivare e supportare tutti i soggetti beneficiari citati, a prescindere dalla tipologia di attività svolta, nell’adozione di misure dirette a contenere e contrastare la diffusione del virus Covid-19.
2.2 Ambito oggettivo di applicazione
Il comma 1 dell’articolo 125 prevede che il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione spetta in relazione alle «spese sostenute nel 2020 per la sanificazione degli ambienti e degli strumenti utilizzati, nonché per l’acquisto di dispositivi di protezione individuale e di altri dispositivi atti a garantire la salute dei lavoratori e degli utenti».
Il successivo comma 2 dell’articolo 125 del decreto contiene un elenco esemplificativo di fattispecie riferibili alle precedenti categorie. Pertanto, è possibile individuare due categorie di spese:
a) quelle sostenute per la sanificazione degli ambienti nei quali è esercitata l’attività lavorativa e istituzionale o per la sanificazione degli strumenti utilizzati nell’ambito di tali attività;
b) quelle sostenute per l’acquisto di
i. dispositivi di protezione individuale, quali mascherine, guanti, visiere e occhiali protettivi, tute di protezione e calzari, che siano conformi ai requisiti essenziali di sicurezza previsti dalla normativa europea (comma 2, lettera a));
ii. prodotti detergenti e disinfettanti (comma 2, lettera b));
iii. dispositivi di sicurezza diversi da quelli precedenti, quali termometri, termoscanner, tappeti e vaschette decontaminanti e igienizzanti, che siano conformi ai requisiti essenziali di sicurezza previsti dalla normativa europea, ivi incluse le eventuali spese di installazione (comma 2, lettera d));
iv. dispostivi atti a garantire la distanza di sicurezza interpersonale, quali barriere e pannelli protettivi, ivi incluse le eventuali spese di installazione (comma 2, lettera e)).
2.2.1 Spese per attività di sanificazione degli ambienti e degli strumenti
Con riferimento alle attività di “sanificazione”, in considerazione della ratio legis del credito d’imposta, deve trattarsi di attività finalizzate ad eliminare o ridurre a quantità non significative la presenza del virus che ha determinato l’emergenza epidemiologica COVID-19. Tale condizione risulta soddisfatta qualora sia presente apposita certificazione redatta da operatori professionisti sulla base dei Protocolli di regolamentazione vigenti.
Fermo restando quanto appena rappresentato, con riferimento alle spese di sanificazione degli ambienti nei quali è esercitata l’attività lavorativa (in concreto) e istituzionale (ad esempio, sala d’attesa, sala riunioni, sala di rappresentanza), nonché alle spese di sanificazione degli strumenti utilizzati nell’ambito di tali attività, considerato che la norma non fa riferimento in modo specifico all'”acquisto” (e, quindi, a modalità di approvvigionamento del bene o del servizio da economie terze), l’attività di sanificazione, in presenza di specifiche competenze già ordinariamente riconosciute, può essere svolta anche in economia dal soggetto beneficiario, avvalendosi di propri dipendenti o collaboratori, sempre che rispetti le indicazioni contenute nei Protocolli di regolamentazione vigenti, come attestato da documentazione interna.
In questo caso, l’ammontare della spesa agevolabile può essere determinata, ad esempio, moltiplicando il costo orario del lavoro del soggetto impegnato a tale attività per le ore effettivamente impiegate nella medesima (documentata mediante fogli di lavoro interni all’azienda). Possono essere aggiunte, ai fini del credito in esame anche le spese sostenute per i prodotti disinfettanti impiegati.
Resta fermo che l’ammontare delle spese di sanificazione degli ambienti e degli strumenti così determinato, in ogni caso, dovrà essere congruo rispetto al valore di mercato per interventi similari.
Sempre con riferimento a questa tipologia di spese per la sanificazione oggetto di agevolazione, le stesse possono riguardare anche strumenti già in dotazione del soggetto beneficiario. L’agevolazione in commento, infatti, riguarda la sanificazione degli strumenti stessi (nuovi o già in uso), non il loro acquisto.
Per talune attività, le spese di sanificazione (degli ambienti e degli strumenti), in quanto costituenti spese ordinarie in relazione alla natura dell’attività esercitata (come, per esempio, nel caso di studi odontoiatrici, centri estetici, etc.) possono essere già previste, a prescindere dall’emergenza epidemiologica da Covid-19. Anche in tal caso – purché si tratti di spese sostenute dal 1° gennaio 2020 al 31 dicembre 2020 -, le stesse rilevano ai fini della determinazione del credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione.
Laddove l’esercizio dell’attività esercitata dal soggetto beneficiario dell’agevolazione preveda lo svolgimento di lavorazioni eseguite presso terzi, con strumenti da mettere a disposizione del cliente solo a seguito del processo di sanificazione, solo le spese, sostenute dal soggetto beneficiario, per le operazioni di sanificazione degli ambienti e strumenti rientrano tra le spese di sanificazione di cui alla lettera sub a).
2.2.2 Spese per l’acquisto di dispositivi di protezione individuale e di altri dispositivi atti a garantire la salute dei lavoratori e degli utenti
Per quanto concerne, l’insieme di cui alla lettera sub b) si rammenta che con la Circolare del 13 aprile 2020, n. 9/E è stato già fornito un primo chiarimento per cui i dispositivi individuali agevolati sono rappresentati da mascherine chirurgiche, Ffp2 e Ffp3, guanti, visiere di protezione, occhiali protettivi, tute di protezione, calzari. Inoltre, per quanto concerne i dispositivi di protezione individuale, per i quali la norma richiede la conformità ai requisiti essenziali di sicurezza previsti dalla normativa europea, si ritiene che solo in presenza di tale documentazione le relative spese sono considerate ammissibili ai fini del credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione. Ai fini delle attività di controllo, pertanto, sarà necessario che i fruitori conservino la documentazione attestante la conformità alla normativa europea.
Con riguardo alle attrezzature, atteso che le stesse possono avere non solo un impiego sanitario, ma anche altre finalità e rientrare tra i beni già utilizzati ante Covid-19, per adempiere ad obblighi di sicurezza sul lavoro, le spese relative alla sanificazione di cui all’articolo 125 di detti strumenti concorrono alla determinazione del credito d’imposta in esame. Ciò in quanto,
- la norma, nel suo dato letterale, si riferisce agli «strumenti utilizzati nell’ambito» dell’attività lavorativa e istituzionale, non distinguendo tra uso sanitario o altro uso, sempre che l’attrezzatura sia inerente all’attività oggetto di agevolazione;
- la finalità del legislatore è quella di contenere, limitare il propagarsi del virus SARS-CoV-2, a prescindere dagli impieghi degli strumenti nell’ambito dell’attività agevolabile.
Considerato che nel caso delle spese di cui all’articolo 125, il legislatore ha fatto genericamente riferimento alle spese sostenute nell’anno 2020, ne deriva che siano agevolabili tutte le spese rientranti nell’elenco di cui al comma 2 dell’articolo 125 del decreto Rilancio, sostenute dal 1° gennaio al 31 dicembre 2020.
Con specifico riferimento alle spese sostenute per l’acquisto di articoli di abbigliamento protettivo, dai molteplici usi, non necessariamente correlati alla sanificazione quali guanti in lattice, visiere ed occhiali protettivi, tute di protezione, etc. – sempre che siano conformi ai requisiti essenziali di sicurezza previsti dalla normativa europea – acquistati per tutto il periodo 2020 anche ante Covid-19, necessari, tra l’altro, a prevenire, contenere la diffusione della malattia Covid-19, in linea con la ratio del legislatore, si ritiene concorrano tra le spese agevolabili di cui all’articolo 125, comma 2, sub) b) del decreto Rilancio.
2.3 Modalità e termini di utilizzo
In considerazione del tenore letterale della disposizione normativa qui in esame, l’ammontare cui parametrare il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione è rappresentato dalle spese oggetto dell’agevolazione qualora sostenute nell’anno solare 2020 (dal 1° gennaio 2020 al 31 dicembre 2020) dai soggetti beneficiari sopra individuati.
La norma dispone che tale credito d’imposta non può superare la misura di 60.000 euro per ciascun beneficiario, nel limite complessivo di 200 milioni di euro per l’anno 2020.
Il limite massimo (60.000 per beneficiario) è riferito all’importo del credito d’imposta e non a quello delle spese ammissibili. Ne deriva che il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione spetterà nella misura del 60 per cento delle spese ammissibili sostenute, ove l’ammontare complessivo delle stesse sia inferiore o uguale a 100.000 euro. Diversamente, nel caso in cui dette spese siano superiori a tale ultimo importo, il credito spettante sarà sempre pari al limite massimo di 60.000 euro.
Poiché, inoltre, la disposizione fa riferimento alle spese sostenute nel 2020, l’agevolazione spetta nel caso in cui il sostenimento sia avvenuto nel corso dell’anno e, quindi, anche antecedentemente alla data del 19 maggio 2020, data di entrata in vigore del decreto legge n. 34 istitutivo del credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione.
Considerato che nel comma 1 viene utilizzata la locuzione «spese sostenute nel 2020», ai fini dell’imputazione delle spese stesse occorre fare riferimento:
i. per le persone fisiche, compresi gli esercenti arti e professioni, e per gli enti non commerciali (nonché per le imprese individuali e le società di persone in regime di contabilità semplificata), al criterio di cassa e, quindi, alla data dell’effettivo pagamento, indipendentemente dalla data di avvio degli interventi e degli investimenti cui i pagamenti si riferiscono. Ad esempio, un intervento ammissibile iniziato a giugno 2020, con pagamenti effettuati sia nel 2020 che nel 2021, consentirà la fruizione del credito d’imposta solo con riferimento ai pagamenti effettuati nel 2020. Per i soggetti in regime di contabilità semplificata che hanno optato per l’applicazione del criterio di cui al comma 5 dell’articolo 18 del decreto del Presidente della Repubblica 29 settembre 1973, n. 600 il pagamento si intenderà effettuato alla data di registrazione del documento contabile;
ii. per le imprese individuali, per le società, per gli enti commerciali e per gli enti non commerciali in regime di contabilità ordinaria, al criterio di competenza e, quindi, alle spese da imputare al periodo di imposta in corso al 31 dicembre 2020, indipendentemente dalla data di avvio degli interventi cui le spese si riferiscono e indipendentemente dalla data dei pagamenti.
Con riferimento agli acquisti agevolabili individuati dalla norma, si precisa che, ai fini della maturazione del credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione e del successivo utilizzo, il beneficiario deve essere in possesso del documento certificativo.
Il calcolo del credito spettante andrà effettuato sulla spesa agevolabile al netto dell’Iva (i.e. sull’imponibile), laddove dovuta. Al riguardo, come chiarito con la circolare n. 34/E del 2016, «il valore degli investimenti realizzati in ciascun periodo agevolato deve essere determinato secondo i criteri ordinari per l’individuazione del costo dei beni rilevante ai fini fiscali previsti dall’articolo 110, comma 1, lettere a) e b), del TUIR, indipendentemente dalle modalità (ordinarie, forfetarie, sostitutive) di determinazione del reddito da parte del contribuente». Pertanto, ai sensi del menzionato articolo 110 del TUIR, l’IVA indetraibile va inclusa nel costo fiscale dei beni cui commisurare il credito d’imposta qui in esame, come avviene per gli oneri accessori capitalizzabili all’investimento principale.
2.4 Opzioni di utilizzo dei crediti d’imposta
Il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione, in base al combinato disposto del comma 3 dell’articolo 125 del decreto Rilancio con l’articolo 122, comma 2, lettera d), del medesimo Decreto, è utilizzabile successivamente al sostenimento delle spese agevolabili:
- in compensazione, ai sensi dell’articolo 17 del decreto legislativo 9 luglio 1997, n. 241 (modello F24);
- nella dichiarazione dei redditi relativa al periodo d’imposta di sostenimento della spesa; o, in alternativa
- entro il 31 dicembre 2021, può essere ceduto, anche parzialmente, ad altri soggetti, ivi compresi istituti di credito e altri intermediari finanziari, con facoltà di successiva cessione del credito.
Al fine di consentire l’utilizzo in compensazione del credito d’imposta di cui trattasi, tramite modello F24 da presentare esclusivamente attraverso i servizi telematici messi a disposizione dall’Agenzia delle entrate, con successiva risoluzione sarà istituito un apposito codice tributo e saranno impartite le istruzioni per la compilazione del modello F24.
In relazione all’utilizzo del credito in dichiarazione dei redditi, occorre fare riferimento alla dichiarazione relativa al periodo d’imposta in cui la spesa per la sanificazione degli ambienti di lavoro e per l’acquisto dei dispositivi di protezione individuale è stata sostenuta. Inoltre, in considerazione della circostanza per cui, ai sensi del comma 1 dell’articolo 125 si fa riferimento alle spese sostenute nel 2020, per utilizzare il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione nella predetta dichiarazione dei redditi, è necessario che tali spese risultino sostenute nel 2020.
Inoltre, ai sensi del comma 3 dell’articolo 125, il contribuente potrà utilizzare il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione per ridurre l’ammontare complessivo delle imposte sui redditi dovute per il periodo di riferimento del sostenimento delle spese oggetto di agevolazione.
Il credito spettante e i corrispondenti utilizzi andranno indicati nel quadro RU della dichiarazione dei redditi relativa al periodo d’imposta nel quale la spesa relativa alla sanificazione degli ambienti di lavoro e per l’acquisto dei dispositivi di protezione individuale si considera sostenuta, specificando sia la quota utilizzata in dichiarazione, sia la quota compensata tramite modello F24 sia la quota ceduta.
L’eventuale credito residuo potrà essere riportato nei periodi d’imposta successivi, ma, in assenza di una espressa indicazione nell’articolo 125 del decreto Rilancio, non potrà essere richiesto a rimborso.
Si rammenta che, come espressamente menzionato nel comma 1 e nel comma 2, lettera d), dell’articolo 122 del decreto Rilancio, il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione può essere ceduto e la cessione è esercitabile «a decorrere dalla data di entrata in vigore del presente decreto e fino al 31 dicembre 2021».
Ferma restando la sussistenza dei requisiti sopra descritti in relazione al fruitore/cedente, il cessionario può utilizzare esclusivamente il credito:
- nella dichiarazione dei redditi relativa al periodo d’imposta nel corso del quale la cessione del credito è stata comunicata all’Agenzia delle entrate;
- in compensazione ai sensi dell’articolo 17 del decreto legislativo n. 241 del 9 luglio 1997.
In relazione al cessionario, la quota di credito non utilizzata nell’anno in cui è stata comunicata la cessione all’Agenzia delle entrate non può essere utilizzata negli anni successivi e non può essere richiesta a rimborso. In tali casi, il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione non utilizzato può essere oggetto di ulteriore cessione solo nell’anno in cui è stata comunicata la prima cessione.
Con riferimento all’utilizzo in compensazione del credito, sia da parte del beneficiario del credito, sia da parte dei successivi cessionari, non si applicano i limiti stabiliti dall’articolo 1, comma 53, della legge 24 dicembre 2007, n. 244 (250.000 euro per i crediti d’imposta da indicare nel quadro RU della dichiarazione dei redditi), e di cui all’articolo 34 della legge 23 dicembre 2000, n. 388.
3 Rilevanza fiscale dei crediti d’imposta
Il comma 3 dell’articolo 125 in commento dispone altresì che il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione non concorre alla formazione del reddito ai fini delle imposte sui redditi e del valore della produzione ai fini dell’imposta regionale sulle attività produttive.
Per ragioni di ordine logico sistematico, si ritiene che il credito d’imposta per la sanificazione e l’acquisto di dispositivi di protezione, oltre a non concorrere, così come letteralmente precisato nella norma, alla formazione del reddito ai fini delle imposte sui redditi e al valore della produzione ai fini Irap, non concorre:
- ai fini del rapporto di deducibilità degli interessi passivi, di cui all’articolo 61 del TUIR;
- ai fini del rapporto di deducibilità dei componenti negativi, di cui all’articolo 109, comma 5, del TUIR.
Diversamente, in assenza di una similare previsione contenuta nell’articolo 120 del decreto Rilancio, il credito d’imposta per l’adeguamento degli ambienti di lavoro, concorre alla formazione del reddito ai fini delle imposte sui redditi e al valore della produzione ai fini Irap secondo le ordinarie modalità disposte per i singoli soggetti fruitori.
4 Quadro temporaneo per le misure di aiuto di Stato a sostegno dell’economia nell’attuale emergenza del COVID-19
Il comma 5 dell’articolo 120 dispone espressamente che il credito è fruibile nel rispetto delle condizioni e dei limiti previsti dalla Comunicazione della Commissione europea del 19 marzo 2020, C(2020) 1863 final.
Le disposizioni previste nell’articolo oggetto di commento si applicano nel rispetto dei limiti e delle condizioni previsti dalla Comunicazione della Commissione europea del 19 marzo 2020 C(2020) 1863 final «Quadro temporaneo per le misure di aiuto di Stato a sostegno dell’economia nell’attuale emergenza del COVID-19», e successive modifiche.
Le misure temporanee di aiuto possono essere cumulate conformemente alle disposizioni di cui alle sezioni specifiche delle stesse e con gli aiuti previsti dai regolamenti de minimis o dai regolamenti di esenzione per categoria a condizione che siano rispettate le disposizioni e le norme relative al cumulo previste da tali regolamenti.
Quanto appena descritto non è riferibile anche al credito di cui all’articolo 125 del decreto Rilancio, in assenza di elementi di selettività della misura.
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I have observed that over the course of making a relationship with real estate homeowners, you’ll be able to get them to understand that, in every single real estate deal, a commission amount is paid. In the long run, FSBO sellers never “save” the commission rate. Rather, they try to win the commission by doing an agent’s task. In this, they expend their money and time to execute, as best they can, the obligations of an adviser. Those responsibilities include exposing the home by marketing, introducing the home to prospective buyers, constructing a sense of buyer urgency in order to trigger an offer, preparing home inspections, dealing with qualification assessments with the mortgage lender, supervising maintenance, and aiding the closing.
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I have observed that over the course of building a relationship with real estate managers, you’ll be able to come to understand that, in every single real estate exchange, a percentage is paid. In the end, FSBO sellers never “save” the commission payment. Rather, they fight to earn the commission by way of doing an agent’s task. In doing this, they invest their money and time to conduct, as best they’re able to, the assignments of an broker. Those assignments include revealing the home through marketing, showing the home to willing buyers, creating a sense of buyer desperation in order to prompt an offer, arranging home inspections, handling qualification checks with the loan provider, supervising fixes, and facilitating the closing.
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I have learned new things from the blog post. One other thing I have seen is that typically, FSBO sellers can reject an individual. Remember, they can prefer to not use your services. But if an individual maintain a gradual, professional relationship, offering help and being in contact for about four to five weeks, you will usually manage to win a conversation. From there, a house listing follows. Cheers
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Interesting article. It is extremely unfortunate that over the last several years, the travel industry has already been able to to deal with terrorism, SARS, tsunamis, bird flu virus, swine flu, and also the first ever true global economic downturn. Through it all the industry has really proven to be robust, resilient as well as dynamic, locating new ways to deal with difficulty. There are usually fresh problems and opportunities to which the industry must again adapt and act in response.
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