Today the Director General of Confindustria, Francesca Mariottiintervened in hearing at the Finance Committee of the Chamber of Deputies on Decree-Law No. 11 of 16 February 2023 on urgent measures regarding the assignment of credits.

DL No. 11, passed on 16 February, brings Disruptive changes to the regulation of so-called building bonuses.

The Superbonus Affair is emblematic of how the appreciable original intention to create a shock in the economy affected by the negative effects of the Covid-19 pandemic, may shipwreck if not supported by a prudent quantification of the coverage costs and a precise delimitation of the scope of intervention.

A tormented affair, in short, whose end is not in sight. Because it is clear that even the recent interventions will need, in turn, umpteen corrections.

Urgency of regulatory intervention is motivated by a concern for the economic dimension assumed by bonuses. In fact, as of 31 December 2022, the tax credits 'generated' by the rebate and assignment options already amount to approximately EUR 105 billion, and their possible increase to EUR 120 billion is foreseen as a result of the longer deadline (31 March 2023) granted to taxpayers to communicate the aforementioned options in relation to expenses incurred in 2022.

The data must, however, be examined in its complexity: these tax credits facilitated works that to a large extent would not have been carried out and have brought tax revenues from these activities into the public coffers (those on the income of those employed in the sector, indirect taxes on materials and products, etc.). I building bonuses, in fact, have favoured the very sustained growth of the construction sector observed in recent years in Italy: the sector's investments (at constant prices) are at 25% higher than pre-Covid, but the sector's value added still remains 26% below 2007 levels. This expansion had positive effects in terms of employment in the construction sector and on employment in general: +213,000 more employed in Q3 2022 than at the end of 2019. We must not overlook then the effects on the supply chain: in 2021 and 2022, the expansion of construction drove the activity of several sectors of Italian industry.

The guidelines of the statistical authorities must be clearly considered (Eurostat and, consequently, Istat) with respect to how these incentives are recorded in public accounts.

The broad transferability of tax credits has made them assets exchangeable, with a relative 'near certainty' of use and payment by the state. Against this consideration, Eurostat specifications lead to consider them credits "payable"(receivable), unless it is proven that a non-negligible amount can be wasted/used.

Credits "payable"must be accounted for as expenditure in the State Budget for their full amount at the time they arise: essentially as taxpayers notify the Revenue Agency of the exercise of the option that generates them, rather than being spread over the broader time frame provided for deductions.

These considerations are inescapable, but they cannot validate the manner in which the sudden freezing of invoice discounting and transfer transactions was implemented.

In fact, breaking a discipline in a few hours - already partly deprived of tax rates and relied on by many families, before many companies - is not a good practice.

Delete tout court - and without a reasonable transitional space - alternative forms of use to deductions has undermined the reliance, planning capacity and investment space of all operators involved.

That is why we have on several occasions, including these days, reiterated the need for prior discussion with social partners and companies: the long and troubled history of these bonuses would have long since allowed a technical round table to be set up to calibrate the necessary adjustments with the needs of families and businesses.

Now, therefore, it is necessary to cope with the emergency and then consider calibrating the incentives differently by restricting their scope.

First of all, it is urgent to act on the transitional regime, with the safeguarding of interventions that are about to start, for which costs have already been incurred and commitments made, and which would be formalised in the days immediately following the publication of the DL, as well as for those that are particularly 'deserving' due to their particular purposes or the peculiar contexts in which they are located.

Specifically, there is a need to protect those who, in good faith, at the date of the DL, had already started the work process.

It would be reasonable to predict, upon conversion into law of DLan amendment to the law to confirm the previous discipline for all transfers for which, within 15 or 30 days from the date of conversion into law of the decree under comment, has been submitted the CILA or the request for building permit.

The second urgency is to ensure the disposal (through assignments) of the large stock of credits already accrued, the amount of which is estimated at around EUR 19 billion.

The manufacturing sector represented by Confindustria is fully prepared to play its part, through reliable and certified platforms, in purchasing credits from supplier companies without adequate fiscal capacity. This would be a significant intervention in order to keep the construction sector and the related supply chain operational, making available liquidity available to the entire production system.

Emergency phase closedIf, , margins were to be seen to allow some form of circulation of the subsidies in question - which are currently suspended - one could consider limiting its operation to a few specific areas.

A broader incentive review project will also have to be evaluated in the context of the decarbonisation and energy efficiency in the real estate sector.

These targets require us to double (+75%) the expected energy savings in the period 2021-2023 compared to the period 2014-2020 thanks to fiscal measures. Italy, in fact, has 12 million buildings equal to 32 million dwellings, 60% of which are over 45 years old.

It is essential to draw up a new medium- to long-term strategy now, that leverages the resources, both in terms of capital and skills, of the entire real estate investment chain, establishing support measures that provide rates that can give price signals to the market and, at the same time, mechanisms for invoice discounting and credit assignment to allow the widest possible take-up, especially for those with less financial means.

It is a matter of initiating a strategy that is sustainable for the public budget and therefore stable and lasting to accompany the green transition in a gradual and steady manner.

One could use this opportunity to define a road map for works aimed at these objectives, spreading them over a defined (and not extendable) time frame, with strict controls on transfers (also through external certifiers) to give operators a certain and stable regulatory system, so that they can plan their investments.

In this regard, Confindustria believes that, once closed this urgent phase, is correct to find the right context for analysis, with objectivity, the real impact of the measures put in place so far on the overall modernisation of the Italian real estate stock, earthquake safety and energy efficiency.