We publish an article by Dr. Gianni Gorno, head of concessional finance at GFA Corporate source, a trusted partner for businesses, with years of experience in the world of concessional finance and corporate finance. GFA Corporate source has a wide knowledge of the financial market that allows it to be a point of reference for SMEs wishing to gain new competitive advantages.
Maintenance of Expertise files in the light of the changes introduced by Circular 9/E of July 2021
In 2018, as the opening theme song of the CHANGE FOR GROWTH conference aimed at businesses, to disclose the news of the Industry 4.0 Plan, we chose the song "Changes" by Vasco Rossi. The song perfectly communicates the need for change, which the Entrepreneur must make his own in order to undertake the digital transformation supported by the 4.0 tax breaks. Then thanks to the help of Claudio Vivante and the T4SM team we were able to create a beautiful opening video that you can see at the top of this article.
"Changing machine is very easy..." means that making a 4.0 investment cannot be limited only to the investment in production machinery. In fact, the law requires the company to proceed to interconnect the new machine in a 4.0 environment. Therefore, in order to create a 4.0 company, it is necessary (for those who do not already own one), in addition to the "machine", to make an investment in a company information system that allows the interconnection and data exchange between software and production assets.
The legislator has not set a deadline for the interconnection requirement, but allows the benefit to be enjoyed even after the purchase of the asset, when the machine becomes part of the company's information system. Very often, making an interconnection means proceeding to a software selection that allows you to identify the management program suitable for your production context.
Circular 4/E of March 2017 (the main interpretative act implementing 4.0) is clear: interconnection is a fundamental requirement to take advantage of the tax benefit, and this requirement must be maintained over time. Even more exhaustive is MISE Circular No. 177355 of May 23, 2018, which states, "a requirement that, it is barely worth noting, for the purposes of maintaining the right to the benefit, will have to be present, evidently, also in the tax periods following the one in which the asset is interconnected."
All clear, except for a fundamental point never addressed by the Legislator, by Mise, and by the Revenue Agency: what happens in the event of a control? In reference to the interconnection will be verified the moment in which the control takes place? Or will it be necessary to demonstrate the maintenance?
Finally, with the circular of the Inland Revenue 9 / E, published July 23, 2021, the doubts are resolved: "In this regard, it is clarified that, for the purposes of subsequent controls, it must be care of the beneficiary company to document, through adequate and systematic reporting, the maintenance, throughout the period of enjoyment of benefits, the characteristics and requirements. Therefore, it is established that the beneficiary has not fulfilled its obligations by merely carrying out the appraisal/attestation/self-declaration certifying that the machinery has been interconnected, but must demonstrate that the requirements have been maintained during the inspection. The "novelty" of Circular 9/E is part of a logical reasoning that conceives interconnection as a continuous process. The survey photographs the initial moment that assigns the right to enjoy the benefit, but the interconnection must "live" in the production reality. Further clarification contained in the July Circular is the requirement that the requirements be maintained "throughout the period of enjoyment of the tax benefit."
This clarification can become a problem for those who understood the interconnection as a formal requirement to access the benefit and not as a digital transformation of their Business.
In recent years, I have often come across technological solutions that formally complied with the requirement but which, in substance, gave no benefit to the beneficiary company.
A useless system, or merely instrumental to the benefit 4.0, is not a solution but the assumption of a risk: an unused system, in the light of the provisions of Circular 9 / E, can lead to the revocation of the benefit with the application of penalties.
Circular 9/E has prompted us to implement a service that GFA had been thinking about for some time: the maintenance of the expertise file. With the introduced prescription "to document, through an adequate and systematic reporting" the maintenance becomes an absolute necessity.
For our Customers, but not only, we thought to make an annual visit aimed at verifying the current state of the machine 4.0 and its interconnection. The maintenance will certify, through adequate and systematic reporting, any changes from the initial situation declared in the report.
The legislation, in fact, does not prohibit changes to the information system over time, but it will be necessary to make them known through the maintenance activity.
Finally, maintenance can represent for those who have understood interconnection as only a formal requirement, the opportunity to undertake the digital transformation of their company.
The central point is in the entrepreneur's willingness to change, as Vasco reminds us, "You can only change yourself. It seems little but if you could. You would make the revolution."
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→ Visit the GFA Corporate source website and learn about the expert file maintenance service to demonstrate continued compliance