The Italian National Social Security Entity (Istituto nazionale della previdenza sociale, ‘INPS’), with Message no. 2923 of 10 August 2023, provided important clarification relating to the cumulation of the ‘NEET’ (persons ‘Not in Education, Employment or Training’) incentive, connected to permanent recruitment carried out from 1 June to 31 December 2023, with other measures that exempt or reduce the funding contribution rates provided for by current legislation, limited to the period of application of the same.
With Article 27 of Italian Law no. 85/2023, converting into law Italian Decree-Law no. 48/2023 (the Employment Decree), a new financial incentive was introduced for the permanent recruitment, between 1 June to 31 December 2023, of young people under 30 who are not in education, employment or training.
The above-mentioned incentive was introduced to support youth employment. The rule, in fact, grants the employer the right to an incentive, for a duration of 12 months, in the amount of 60% of the gross monthly salary taxable for social security purposes paid to the worker for permanent recruitment within the above-mentioned period of time of persons falling within the category of so-called NEETs.
In particular, the incentive is granted for the recruitment of young people who, on the date of recruitment, meet the following requirements:
The incentive applies, on application to be submitted on the INPS website, for permanent recruitment, including through agencies and under professional apprenticeships.
Cumulation with other tax relief
With specific regard to the possibility of cumulation with another tax relief, the same article specifies that in this case the incentive is granted in the amount of 20% of the gross monthly salary taxable for social security purposes.
The Message under consideration has clarified, in particular, that the reduction of the incentive to 20% in the event of cumulation with other reliefs must be understood not in an objective sense, but in a subjective sense, i.e., it is limited only to cumulation with other measures that entail a benefit for the employer who intends to proceed or who has proceeded with the recruitment.
Consequently, therefore, the aforementioned reduction cannot be applied in cases where, for the same worker, there is an exemption from the share of social security contributions for disability, old age and surviving partners (invalidità, la vecchiaia e i superstiti, ‘IVS’)(under Article 1, paragraph 281, of the 2023 Budget Law, as supplemented by Article 39 of Italian Decree-Law no. 48/2023).
In light of this interpretation, therefore, where the parties interested in the recognition of the incentive have already forwarded to the Entity a specific on-line request for the reservation of resources, stating that they wish to take advantage of the incentive in combination with other reliefs, thus referring to the partial exemption of the employee’s share of IVS social security contributions, they may now cancel this request.
The technical procedures for using the incentive
The INPS has also provided indications regarding the procedure for cancelling the request sent, after which it is necessary to submit a new application in which the option of using the incentive in question “exclusively” must be indicated. This procedure will result in the grant, without prejudice to compliance with all legitimate requirements, of the incentive under discussion in an amount equal to 60% of the taxable salary.
Finally, as already provided for by Circular no. 68/2023, the INPS has confirmed that requests received in the 15 days following the release of the on-line incentive request form will be subject to a one-off delay in cumulative processing, which will be carried out in September 2023. Otherwise, requests relating to permanent recruitment carried out between 1 June 2023 and 30 July 2023 (i.e. the day before the on-line form was released) and received within 15 days following the release of the on-line forms (i.e. by 15 August 2023) will be processed according to the chronological order of the date of recruitment.
Requests concerning recruitment starting from the day the on-line form was released (31 July 2023) will be processed according to the general criterion, represented by the chronological order in which the application was submitted.
Until the date of processing, the requests can be cancelled by the same interested party; if a party wants to amend the content, it is necessary to cancel the request in question and then submit a new one.