Article 19 of Law Decree no. 73/2021 (Sostegni bis Decree) introduced a tax incentive for capital increases occurred in FY 2021:

  • capital increases up to €5 million occurred in FY 2021 benefit from a 15% notional interest deduction (Super NID or Super ACE) instead of the 1.3% ordinary NID
  • maximum tax benefit for CIT taxpayers will be equal to €180.000 (€5 million x 15% Super NID x 24% CIT)
  • recapture rules have been introduced to prevent that temporary capital increases can benefit from Super NID


Super NID can be:

  • deducted from CIT tax base
  • converted into a tax credit

Once communicated to the Italian tax authorities, starting from the day following the capital increase, the tax credit can be:

  • offset whit other taxes
  • asked for refund
  • transferred to third parties
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