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Superbonus 110%, new clarifications on deductions. The faq Enea

Answers to the most frequently asked questions relating to the ENEA website have been published super bonus 110%, after publication in the Gazzetta dei Ecobonus Requirements Decrees and Certifications.

It is for the moment of nine faq who seek to clarify doubts and address various aspects including:

  • the amount of the bonus for works started before 1 July;
  • the superbonus for condominiums as a towed intervention;
  • the execution of several secondary interventions;
  • the requirement of the pre-existence of a winter heating system;
  • the release of the certificate of the building’s energy performance, APE.

Please note that in order to take advantage of the superbonus, energy saving interventions must ensure the building improvement of two energy classes, compared to the pre-existing one. From here, the qualified technician who follows the work must draw up two energy performance certificates. One before the start of the work, the other at the end.

Superbonus 110%: driving interventions and towing interventions

Legislative Decree 34/2020, the so-called Relaunch decree, with Article 119, introduced a 110% reinforced deduction for energy saving and seismic risk reduction interventions.
The Revenue Agency with the circular n ° 24 / e 2020 distinguishes between leading interventions and trailed interventions.
The former are subsidized with 110% regardless of the execution of further interventions. On the contrary, the so-called towed ones, to be facilitated must be performed together with at least the towing ones.
Specifically, the interventions must be carried out on buildings intended for housing. Expenses must be incurred between 1 July 2020 and 31 December 2021.
The driving interventions I’m:

  • thermal insulation interventions on building envelopes;
  • replacement of winter air conditioning systems on common areas;
  • replacement of winter air conditioning systems on single-family buildings or on property units of functionally independent multi-family buildings;
  • anti-seismic interventions.

The 110% super bonus is also due for other interventions, if performed together with at least one of those listed above. They are considerate towed the following interventions:

  • energy efficiency interventions;
  • the installation of photovoltaic solar systems;
  • installation of infrastructure for charging electric vehicles.

Superbonus 110 interventions started before 1 July

For the purpose of 110%, does not detect the date of execution of the work but that of sustaining the expenses connected to them.
Therefore, the rule, in essence, does not refer to the start date of the works but only sets the condition that the deduction applies to expenses incurred starting from 1 July 2020 and up to 31 December 2021.
For example, with jobs started in June but paid for in July 2020, there is no obstacle at 110%. Naturally in compliance with the additional conditions provided by the legislation.

Superbonus 110% condominiums

Even before the introduction of the 110% superbonus, for expenses related to interventions on common parts of condominium buildings falling in seismic zones 1, 2 and 3 jointly aimed at reducing the seismic risk and energy requalification, a deduction of up to 85% of the costs incurred is due.
We are talking about the cd superbonus condominiums, provided for in Article 14 of Legislative Decree 63/2013, paragraph 2-quater.1. Can it be considered as a towed intervention for the purposes of 110%?
According to Enea, the energy efficiency intervention indicated in the aforementioned paragraph 2. quater of article 14 affects more than 25% of the gross dispersing surface of the common parts of a condominium building and therefore, it has the characteristics of the driving intervention provided for by paragraph 1 of art. 119. Also anti-seismic interventions they are included pursuant to paragraph 4 of art. 119 of the “relaunch decree” among the driving interventions.
So, the superbonus condomini it cannot be considered as a driven intervention.

Execution of several driving interventions

Is it possible to carry out several driving operations at the same time? For example, in addition to the thermal insulation system, is it possible to follow interventions to reduce the seismic risk? The answer is yes. In fact, as clarified in the circular of the Revenue Agency 8 August 2020, n. 24 / E (see paragraph 4):
In the event that several interventions that can be facilitated are carried out on the same property, the maximum deductible expense limit will be the sum of the amounts provided for each of the interventions carried out.”

Pre-existence requirement of a previous heating system

To request the 110% superbonus but also the ordinary eco-bonus, the building being worked on must already be equipped with a heating system that works in the environments where the facilitated intervention is carried out. This condition is required:

  • for all types of facilitated interventions;
    with the exception of the installation of solar collectors for the production of hot water and biomass-powered generators and solar screens.

In any case, Enea reiterates that the Legislative Decree 48/2020 amended art. 2, paragraph 1, letter l-tricies of Legislative Decree 192/05 which currently defines the heating system:

fixed technological system intended for winter or summer air conditioning services of the rooms, with or without the production of domestic hot water, or intended only for the production of domestic hot water, regardless of the energy vector used, including any production, distribution, storage and use systems as well as the regulation and control organs, possibly combined with ventilation systems. Systems dedicated exclusively to the production of domestic hot water serving individual residential units and similar are not considered thermal plants”.

For the purpose of verifying the condition required for the eco-bonus and the Superbonus, the winter air conditioning system must be fixed. It can be powered by any energy carrier and has no limits on the lower minimum power.

Furthermore, for the same purposes, the plant must be functional or reactivable with maintenance, even extraordinary.

EPA before and after the intervention

110% is due if the works carried out allow the improvement of two energy classes of the building or, if not possible, the achievement of the highest energy class. The leap in energy class is proven by the preparation of the energy performance certificates (APE) before and after construction.
The construction manager and the designer can sign the APEs used only for the purposes of 110% tax deductions which do not need to be deposited in the land registry of heating systems.

By what criterion should the energy classes be determined?

The energy classification criterion to be used is that provided for by the decree of the Minister of Economic Development in agreement with the Minister of the Environment and Protection of the Territory and the Sea, the Minister of Infrastructures and Transport and with the Minister for Simplification and public administration, June 26, 2015, or the criterion provided for by the corresponding regional regulation provided that the regions declare that the same energy classifications are obtained.

At this link you can download the Enea Faq shared by the Ministry of Economic Development and the Revenue Agency.

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