The 2026 Budget Law confirms the return of Italy’s hyper-depreciation scheme (Iperammortamento), an Italian tax incentive available for qualifying investments by businesses resident in Italy and permanent establishments located in Italy. It replaces the Transition 4.0 and 5.0 tax credits with an enhanced tax deduction based on an increase in the depreciable cost of qualifying capital assets of up to 180%. For those managing IT infrastructure, this translates into a tangible opportunity: server clusters, storage infrastructure, backup and disaster recovery systems, cybersecurity solutions, and virtualization platforms may qualify for significant tax relief even when they replace outdated infrastructure that remains critical to business continuity.
The aim of this article is to answer a very specific question: is it possible to migrate from VMware to a Proxmox VE cluster, or build a new one, improve security and business continuity, and at the same time take advantage of the 2026 hyper-depreciation scheme? The answer is yes. Let’s look at why Proxmox VE, integrated into an AXOL Server cluster, represents a combination that is particularly well suited to the requirements of the 2026 hyper-depreciation scheme for hardware and software capital assets.
What will actually change with the 2026 hyper-depreciation scheme
Under the 2026 Budget Law, hyper-depreciation once again becomes a key tool for investment in digital infrastructure. New tangible and intangible capital assets, provided they are interconnected with business systems and supporting digital transformation, may benefit from a cost increase of up to 180%, with a direct impact on tax deductibility.
The scope of the incentive explicitly includes computing infrastructure, data storage and transmission systems, and, most significantly, IT security infrastructure, including systems for backup, disaster recovery, and business continuity. This is precisely the scope of a modern virtualization cluster designed for mission-critical environments.
Requirement for the 2026 hyper-depreciation scheme and tax benefits
The requirement that goods be produced exclusively in the EU, previously defined for tangible goods listed in Annex IV and intangible goods listed in Annex V, was definitively removed by Decree-Law No. 38 of March 27, 2026.
Businesses resident in Italy and permanent establishments located in Italy may be eligible for hyper-depreciation on qualifying Industry 4.0 investments under Annexes IV and V, subject to the applicable requirements. Eligible assets may include:
- software and platforms supporting digital transformation;
- computing infrastructure;
- OT/IT cybersecurity infrastructure;
- backup, disaster recovery, and business continuity systems;
- redundant and clustered architectures for mission-critical applications.
This incentive is valid from January 1, 2026, to September 30, 2028. For goods, “the date of delivery or shipment for movable property” applies, an aspect to keep in mind if you have an order in progress.
Why Proxmox VE falls within the scope of the 2026 Budget Law
Within the context of the 2026 hyper-depreciation scheme, Proxmox VE is a solution that fully aligns with the requirements for digital capital assets. When deployed within an AXOL Server cluster, it provides an integrated solution for virtualization, data security, business continuity, and optimization of operating costs.
For many companies considering migration from VMware, the issue is no longer merely technical but strategic: reducing total cost of ownership without compromising reliability, control, and scalability. Proxmox VE is a mature virtualization platform, based on KVM and containers, designed for clustered environments, high availability, and advanced storage management.
AXOL’s role: not just servers, but tailored projects
A common mistake is to view a cluster as simply the sum of its hardware nodes. In reality, what makes the difference, including for the purposes of the tax incentive, is the overall architecture: redundancy, data replication, automatic failover, and integration with corporate management and monitoring systems.
It is at this level that AXOL Server stands out. The server clusters are assembled entirely in Italy, at the company’s Ivrea site, and designed as complete infrastructure solutions rather than generic hardware. Our specialized expertise in Proxmox VE enables us to build solutions that are consistent from both a technical and regulatory perspective, reducing the risk of investments that do not meet the requirements of the 2026 hyper-depreciation scheme.
Hyper-depreciation 2026: a practical example and tax benefits
The surcharge percentages provided for by law are particularly significant:
- +180% on the portion of investments up to 2.5 million euros → for a company subject to the standard 24% IRES rate, the theoretical additional tax savings amount to 43.2% of the subsidized portion;
- +100% for the portion exceeding 2.5 and up to 10 million euros → theoretical additional tax savings of 24%;
- +50% for the portion exceeding 10 million euros and up to 20 million euros → theoretical additional tax savings of 12%.
These percentages reflect the potential IRES impact of the tax surcharge and do not represent an immediate tax credit or deduction. The actual benefit depends, among other factors, on the company’s tax status, the portion of the investment that falls into each tax bracket, and the depreciation schedule.
Let’s imagine that a company needs to invest in a server cluster running Proxmox VE. This hyperconverged system qualifies as a capital asset under the 2026 hyper-depreciation scheme and is eligible for tax benefits. Although the “Made in the EU” requirement has been removed, data sovereignty remains central. Choosing an infrastructure such as AXOL clusters with Proxmox VE means that you retain control over your data, reducing risks associated with regulations in other countries and increasing predictability in security management.
Example of a server cluster:
| AXOL + Proxmox VE Cluster – Investment | Amount |
|---|---|
| Ordinary investment cost | €200,000 |
| 2026 hyper-depreciation increase (+180%) | €360,000 |
| Total theoretical tax-deductible basis | €560,000 |
| Theoretical ordinary IRES savings (€200,000 × 24%) | €48,000 |
Theoretical additional IRES savings from hyper-depreciation (€360,000 × 24%) | €86,400 |
| Total theoretical IRES effect | €134,400 |
The figure of €86,400, equal to 43.2% of the original investment, therefore represents the theoretical additional IRES benefit attributable to the 180% increase. This is not an immediate refund: the benefit is realized over time in accordance with depreciation rules and requires the presence of sufficient taxable income.
The real decision-making lever: reducing risk, not just costs
For an IT manager or business decision-maker, the point is not simply to “spend less.” It is to spend more wisely by reducing exposure to operational risk and improving the overall resilience of the infrastructure (and, why not, to sleep soundly knowing that the data is safe).
In 2026, hyper-depreciation enables companies to build scalable infrastructure, ready for AI, Industry 5.0, and digitalization, without placing the full burden of the investment on the income statement and without being tied to increasingly expensive licensing models. It is a time-limited opportunity, with clear rules and measurable benefits.
Turn the 2026 hyper-depreciation scheme into a concrete decision
The final question is simple: does it still make sense to maintain an expensive, inflexible, and poorly scalable infrastructure when there is a robust alternative that is backed by tax incentives? In the current climate, the answer is increasingly “no”.
The choice is not between upgrading or not upgrading, but between being at the mercy of change or managing it proactively. For this reason, before making any decision, the most sensible course of action is to analyze the existing infrastructure and simulate a real-world scenario.
AXOL Server offers one hour of free technical consultation and the opportunity to configure a Proxmox VE cluster online, allowing you to assess the practical implications, costs and benefits before making an investment.
Now the choice is entirely yours.
Gazzetta Ufficiale and Annexes IV and V
The Budget Law was published in the Gazzetta Ufficiale on December 30, 2025. Please refer to Annexes IV and V concerning assets supporting the technological and digital transformation of Industry 4.0 enterprises, and the list of intangible assets supporting digital transformation.
