Covid State Aid self-declaration, new model with simplifications: better late than never

Covid State Aid, the new model for self-declaration arrives: from October 27, green light for the simplifications requested by insiders. The provision of the Revenue Agency of 25 October 2022 specifies which subjects can be exempted from sending certain data.

Covid State Aidfrom 27 October it is possible to use the new self-declaration model for sending: by inserting the box “ES”become concrete simplifications requested for months by professionals. To specify what are the subjects that can be exempt from sending some data and the operating instructions is the provision of the Revenue Agency of 25 October 2022.

“The proposals of the National Council have been accepted which make, in the absolute majority of cases, the compilation of the self-declaration decidedly easier”with these words he commented on the news Elbano de NuccioPresident of the National Council of Chartered Accountants and Accounting Experts who had become spokesman for theneed to streamline compliance.

It is undoubtedly a positive result: but also times have a weight and the decision came later about 6 months from the first indications provided by the Revenue Agency and just over a month from the deadline set at November 30.

Revenue Agency – Provision number 398976 of 25 October 2022
Amendments to the self-declaration model for aid in Section 3.1 and Section 3.12 of the Communication from the European Commission of 19 March 2020 C (2020) 1863 final, on the “Temporary framework for State aid measures

support of the economy in the current Covid-19 emergency “, approved with a provision by the Director of the Revenue Agency of 27 April 2022

Covid State Aid, new model for self-declaration: who can take advantage of the simplifications

In the new self-declaration modelwhich can be transmitted starting from 27 October, the box has been inserted “ES”by crossing it you can proceed with sending without completing part A and, therefore, without indicating thedetailed list of Covid aid used: concessions, non-repayable contributions, bonuses.

Not all of them, however, are exempt from sending detailed information. As stated in the provision number 398976 of 25 October 2022they can follow the way of simplification only those who are in the following conditions:

  • from 1 March 2020 to 30 June 2022 they received one or more aids from those listed in table A;
  • for none of the aid received do they intend to benefit from the limits of the Section 3.12 of the Temporary Framework;
  • the total amount of aid received does not exceed the maximum permitted limits of the Section 3.1 of the Temporary Framework expected in the reference period.

In any case, the Revenue Agency specifies:

“They are excluded from the exemption IMU aid listed in the aforementioned part A and, therefore, the corresponding lines must in any case be completed if the registrants have benefited from such aids “.

Covid State Aid, new model for self-declaration: instructions and rules to follow

In the presence of the required requisites, it is up to the obligated subjects choose between two ways of compiling self-declaration of Covid State Aid:

  • that canonicaloriginally envisaged, which provides for the inclusion of all aid received in part A;
  • that simplified which, by ticking the box “ES”relieves the obligation to send all the detailed data on the concessions benefited from through part A of the model.
Revenue Agency – Covid State Aid self-declaration model
Covid State Aid self-declaration model updated to 25 October 2022

The choice must be made taking into account an important clarification:

“It is understood that for the aids listed in part A, for which the fields” Sector “and” Activity code “are present, it is possible to communicate through the self-declaration the data necessary to allow their registration in the National Register of State Aids (RNA ). For these aids, the declarant is exempted from completing the State aid form present in the INCOME 2022 form. If the “ES” box is filled in, however, the obligation to complete the “State Aid” form present in the INCOME model 2022.

Who has already sent theCovid State Aid self-declaration with the old model, in any case, it does not have to transmit it again with the updated model.

State aid Covid, the simplification of the self-declaration model arrives: better late than never

The simplification of the self-declaration model of Covid State Aid certainly makes theleaner fulfillment and offers a way out of the amount of data to be sent to all those who have not yet done so.

Revenue Agency – Covid State Aid Self-declaration, the instructions updated to 25 October 2022
The instructions on the self-declaration Covid State Aid updated to 25 October 2022

But the novelty also represents yet another stepperhaps the final one, of a long and difficult path:

  • the first Support Decree introduced the fulfillment useful for monitoring compliance with the limits and conditions set out in the EU Temporary Framework, but for more than one year fromFinancial administration no instructions have been received on this data transmission foreseen by article 1 of Legislative Decree no. 41 of 22 March 2021;
  • only on 27 April 2022 with provision number 143438 of 2022 was the template to use to communicate the State aid received and the instructions to follow;
  • the document has turned the spotlight on two aspects: the deadline set in the first instance on 30 June 2022 And the size and complexity of the data to be sent to the Revenue Agency, since last spring the insiders have asked an extension and a simplification;
  • the Ministry of Economy and Finance in several questions for immediate response he expressed doubtsbut the possibility of dialogue, on the deadline to be respected and one clearer closing on simplifications due to the need to comply with Community obligations;
  • one step away from the date set for sending theSelf-declaration of State Aidlast June the timetable was revised and the deadline was set at 30 November. No changes was made, however, to the contents to be sent to the Revenue Agency;
  • alone after 6 months And an apparent total closure on the possibility of streamlining the model, the provision has arrived that makes sending easier.

“The attention received by the top management of the Ministry of Economy and Finance, the Ministry for Economic Development and the Revenue Agency, who have been able to grasp the constructive spirit of true simplification of the proposals put forward, bringing them back, not without difficulty, to the community “.

With these words he commented on the news on President of the National Council of Chartered Accountants and Accounting Experts Elbano de Nuccio.

Without doubt the effort is appreciable, but it is also undeniable that theintervention rather late: for months, experts have been reporting the redundancy of the information requested by invoking it Statute of the rights of the Taxpayer and for years the same Revenue Agencyfinding himself between community obligations and citizens, he reflects on the issue.

In the’disclosure of 10 October 2022with which the CNDCEC anticipated the possibility of a simplification of theself-declaration of Covid State Aidit read:

“The Agency, in agreement with the competent Ministries, is addressing the issue and evaluating, as quickly as possible, the feasibility in light of the complex EU legislation from which compliance is derived”.

The times of bureaucracy, as we know, are long at all levels. But the “As fast as possible” combined with a 6 month wait it sounds like an oxymoron.

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About Eric Wilson

The variety offered by video games never ceases to amaze him. He loves OutRun's drifting as well as the contemplative walks of Dear Esther. Immersing himself in other worlds is an incomparable feeling for him: he understood it by playing for the first time in Shenmue.

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