The Superbonus 110% is one of the energy policy instruments of our country which specifically addresses the issues of energy efficiency and energy performance of buildings, representing at the same time an opportunity for economic recovery. Its rapid gestation and the critical context of application, to which it is addressed, have led to difficulties in the long-awaited application. The various critical issues see a continuous activity of the government bodies in charge of providing answers and clarifications to the various questions formulated, the latest being the circular 30 / E of the Revenue Agency which in over 80 pages provides answers to the doubts of citizens, professionals and businesses.
(by Gianfranco Ossino Engineer and Head of the Observatory for the Digitization of the Environment and Energy) The superbonus is added to existing tools that already generate an annual expenditure for both Ecobonus and Sismabonus interventions exceeding 3 billion euros (source Centro National Council of Engineers Studies - Nov 2020 Report) as highlighted in the slide that collects the average annual expenditure in millions of euros in Italy, in the period 2014-2019, for energy and structural requalification interventions.
By focusing attention on the slide only on the interventions defined as driving the Superbonus 110%, a consistent average annual expenditure was generated:
- for the insulation of the envelope (including the so-called thermal coat) just over 800 million, on average about € 34.000 per intervention;
- for the installation of new air conditioning systems about 752 million, on average about € 31.000 per intervention;
- for structural interventions for the prevention of seismic risk approximately 80 million euros, on average about 3.500 euros per intervention.
To date, the number of construction sites activated is small, it is estimated that around 9 million households could generate a potential additional demand for the 110% Superbonus if the current difficulties, attributable to its rapid gestation and critical context of application, could be overcome. addresses.
The various difficulties in applying the superbonus 110% see a continuous activity of the government bodies in charge of providing answers and clarifications to the various questions formulated, the latest being the circular 30 / E of the Revenue Agency which in over 80 pages provides answers to the doubts of citizens, professionals and businesses. The circular takes up the changes introduced by Decree no. 104/2020 of 14 August and continues by providing clarifying answers on specific questions relating to fundamental topics such as: beneficiaries, types of properties allowed, interventions and spending limits, option for sale or discount on invoices and compliance visa. Below is a summary of some of the contents of the circular and for the necessary details, please refer to the circular itself.
In a nutshell, the novelties of the August decree that the circular takes up (see circular Chapter 1) concern:
- clarification of the notion independent access from the outside;
- clarification on the 110% superbonus application in the areas affected by seismic events for redevelopment interventions and eventual accumulation with current instruments for reconstruction;
- condominium meetings, reduced quorum (1/3 of the ownership) necessary for the condominium majorities that approve the works;
- asseverations by technicians, simplifications in the case of only interventions on the common parts.
Below is a non-exhaustive summary of the contents of some clarification responses contained in the circular:
- clarification on the beneficiaries with reference to natural persons carrying out business activities or arts or professions when the interventions concern properties falling within the private sector (see circular par. 2.1.3 and 2.1.6);
- non-profit organizations, voluntary organizations and social promotion associations can benefit from the Superbonus without any limitation in relation to the type of property involved in the intervention (see circular par. 2.1.1);
- autonomous public housing institutes (IACP) for interventions admitted to the superbonus:
- it also includes expenses incurred from 1 January 2022 to 30 June 2022 (see circular par. 2.1.2);
- split payment is not applied to the sale of goods and services if you opt for the "discount on the invoice" (see circular par. 5.3.4);
- the installations benefiting from the Superbonus also include the internal thermal insulation system in buildings subject to historical, artistic or landscape constraints (see circular par. 3.1.5);
- interventions on a pertinence can benefit from the Superbonus in compliance with all the requirements established by article 119 of the Relaunch decree (see circular par. 4.1.1);
- clarifications regarding the condominium:
- in the presence of arrears, the superbonus is not granted (see circular letter par. 5.1.2);
- in the presence of both driving and towing interventions, the improvement of two energy classes must be verified by considering the building in its entirety, taking into consideration all the interventions, both driving and towed (see circular par. 5.2.5)
The 2021 Budget Law, officially approved, on the subject of Superbonus provides for a series of provisions, the main ones being listed below:
- extension until 30 June 2022 and, for buildings that completed 60% of the works in June of that year, until 31 December 2022;
- deduction also for interventions for the insulation of the roof;
- definition of functionally independent real estate units;
- deduction for buildings without APE;
- deduction for the elimination of architectural barriers;
- tax deduction for IACPs until 31 December 2022;
- extension of the ordinary seismabonus for interventions for which the building permit has been issued by 31 December 2021;
- deduction also for photovoltaic solar systems on structures appurtenant to buildings;
- greater detail for the cost limits relating to the installation of infrastructures for recharging electric vehicles in buildings;
- deduction for buildings consisting of two to four distinctly stacked real estate units, even if owned by a single owner or co-owned by several individuals;
- changes to the approval process for interventions for condominiums;
- no longer the obligation of exclusive professional policies for the declarations of professionals;
- obligation to display a sign on site indicating: “Access to state incentives provided for by law no. 17, 2020 percent superbonus for energy efficiency or earthquake-resistant interventions ";
- extension until 31 December 2022 for alternative options to the direct use of the super bonus (discount on invoice and credit transfer).
It is inevitable that such a complex initiative, such as Superbonus 110%, also entails some implementation difficulties that can be found:
- in the complexity of the procedures and the stringent conditions for access to incentives;
- in the complex process, the feasibility outcome of the request depends on documents on the property that are most often difficult to find (Municipal Technical Office) and with the current pandemic the situation is even more critical;
- in the heavy documentary load required of property owners and professionals, in the design and execution phase of the works and in the certification phase of the activities carried out;
- in a further possible burden, in terms of documents to be produced, which can be generated if you decide to transfer the tax credit to a bank;
- in the credit recovery risk that the Inland Revenue can claim from the client on any discrepancies that can be contested within eight years from the year following the year of use of the superbonus.
Considerations
The current duration December 2021 is insufficient for such a complex initiative and the application is limited only to the prescribed properties which represent a subset of the entire real estate portfolio, it would be desirable to extend it beyond 2022 and to apply it to the entire real estate portfolio. of our country.
As Aidr, in addition to disseminating information on the 110% superbonus, we also do our best to hear public opinion on this praiseworthy initiative and help promote its use. Specifically, we have implemented two initiatives, namely:
- we have paid attention to how to use the 110% Superbonus by involving our readers by launching an online consultation for this purpose and the results of which will allow us to highlight critical issues and proposals that we will bring to the attention of the institutions within an online event dedicated to the Superbonus ;
- we promote the “Relaunch Italy” platform which is essential support for carrying out all activities, respecting the parameters set by law. A technology at the service of professionals, the software has in fact been designed to support all those involved in the project step by step: companies carrying out the works, manufacturers and wholesalers, construction managers, technicians, architects, designers, insurers, tax observers for visas. of compliance.