CILAS after June 30, 2022?
On June 22, I published the article “Superbonus 110% and one family: Pay attention to the datesthrough which I tried to deal with the matter
Deadlines Super Bonus 110% It depends only on the current version of the standard.
Superbonus 110% and One Family: Deadlines
related to one family (called an error”huts”), there is no doubt that the previous version of Article 119, paragraph 8 bis of Decree-Law No. 34/2020 (Restart Decree), amending Law No. 234/2022 (Budget Law), was expecting time horizon On the superbonus is quite obvious.
with input Paragraph 8 bis There was a system of exceptions to the general rule setting the bonus expiry at 110% in 30 June 2022. In particular, it remains on the beneficiary the subject referred to in Article. 119, paragraph 9, letter b) of the re-run decree (le normal peopleoutside the exercise of commercial activities, arts and professions, on the maximum number of two real estate units, without prejudice to the recognition of deductions for interventions made to the common parts of the building), and the possibility of expansion to December 31, 2022 In the event that as of June 30, 2022 (the bonus expiration date), the 30% of the entrance.
The Decree-Law N. 50/2022 This latter date was recently changed by stipulating that to reach December 31, 2022 it would be sufficient to complete 30% of the total intervention by September 30, 2022.
In the last part of the article “Superbonus 110% and One Family: Pay Attention to the Dates” I cast a doubt, stating that it is not instant clarity
Possibility Never interfere Great bonus for single family homes after, after June 30, 2022. Precisely for this reason, I also admitted that the wisest choice is to wait for one of the options The official interpretation of the revenue agency.
The interpretation arrived immediately in the new Circular No. 23 / A on June 23, 2022 (after my article).
Superbonus 110% and one family: Para 8bis
Before I see what the revenue agency says, I’ll try to make one Analytical effort and present one
interpretative Which is based only on the law. regarding 110% of additional interventions on single family homes The following paragraphs of art. 119:
- Para 1 – which sets the expiry of the Environmental Bonus interventions at 110% on June 30, 2022;
- Paragraph 2 – which sets the deadline for environmental interventions at 110% to June 30, 2022 (“jointly with the driving forces”);
- Para 4 – which sets the deadline for the intervention of sismabonus at 110% to June 30, 2022;
- Paragraph 4 bis – which sets the deadline for the intervention of 110% sismabonus to June 30, 2022 (“jointly with 110% sismabonus);
- Paragraph 8 bis – which are limited to single-family buildings, stipulates “For interventions made on real estate units by natural persons referred to in paragraph 9, letter b), a discount of 110 percent is also due for expenses incurred until December 31, 2022, provided that as of September 30, 2022 the works have been carried out in their favor. at least 30 percent of the total intervention, the calculation of which may also include works not facilitated in accordance with this Article“.
From a lexical point of view, it is clear that the deadline referred to in paragraph 8 bis with the deadline for the other paragraphs leaves “Discovery” The Between 30 June and 30 September 2022. But the same can be thought of for the beneficiaries referred to in Art. 119, paragraph 9, letters c) and d) of Legislative Decree No. 34/2020 (IACP and Undivided Housing Cooperatives) which has been shown that if the works are carried out on 30 June 2023 for at least 60% of the total intervention, then 110% reward will also be due for the expenditures incurred by 31 December 2023. But in this case there is no doubt that the works will also start until June 30, 2023, so the period prior to June 30, 2022 (the general expiration date of the Super Bonus) is definitely not “disclosed”.
Superbonus 110%, one family and maturity: Conclusions
Although, as noted, the rule is not written in the best way, one Not a very strict interpretation But certainly closer to the legislator’s percentage, this leads me to believe that even a business that started communicating or another building address after June 30, 2022 will be able to use the premium bonus, but provided that 30% of the work is (otherwise no bonus).
It must be remembered that to prove achieving 30% of the SAL, you will need one Technical Report by Professionals Who, again, will find himself with a daunting task that will put him in the middle
very dangerous triangle
Client – Company – Revenue Agency.
Superbonus 110%, single family and maturity: What the tax authorities say
As expected, the answer to doubt came with
Revenue Agency Circular 23 June 2022, n. 23 / AH Which in the foreground, fixingTime horizon for using the super reward For different beneficiaries, acknowledge that the deadline for single family homes is September 30, 2022 (so it is certainly possible to submit CILAS also after 30 June 2022) and that if by this date work has been carried out for at least 30% of the total intervention, where unsupported work with 110% bonus can also be included, the deadline will be extended to December 31, 2022.
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