The Firm’s specialisations
Recovery of aggregates and demolition rubble, remediation works, earthmoving, landfills and treatment plants: a sector where the investment in plant, the financial guarantees and the traceability obligations are woven into the financial statements.
The investment issue
It is not a single purchase but a set of components with different useful lives: masonry works and yards, crushing and screening unit, electrical systems, dust abatement systems and weighbridge. Separating them on initial recognition produces correct depreciation and opens access to the incentives for the assets that actually qualify.
The most frequent mistake is recognising everything as a «generic plant». Civil works follow depreciation coefficients different from those of machinery; management software belongs, if anything, among intangible assets, while sensors and control systems remain tangible assets, and the distinction matters because the lists annexed to the incentive legislation are two and separate. As for the waterproofed slab, its construction cost is a work with its own useful life and is depreciated; the land on which it stands, by contrast, is not depreciated, unless its usefulness is bound to be exhausted over time, as happens with quarries and with sites used as landfills.
Slab, retaining walls, internal roads and weighbridge: depreciation over their own useful life, keeping separate the value of the land, which as a rule is not depreciated.
Crusher, screen, conveyors and magnetic separator: the incentive-eligible core of the investment, provided the asset appears in the lists annexed to the legislation and interconnection is in place.
Dust abatement, first-flush rainwater tanks, monitoring: costs often imposed by the permit, to be distinguished between maintenance and increase in value.
References: art. 102 and art. 110, comma 1, lettera b), of d.P.R. 22 dicembre 1986, n. 917 (TUIR, the Italian income tax code); depreciation coefficients of the d.m. 31 dicembre 1988; Italian accounting standard OIC 16, on depreciation by components and on land whose usefulness is bound to be exhausted; art. 1, commi 427-436, of legge 30 dicembre 2025, n. 199 (2026 Budget Law) and its implementing decree, for the uplift of the depreciable cost of new 4.0 capital assets.
Permits and guarantees
Yes, and in two ways. The surety policy or bank guarantee provided to obtain the permit generates accrual-based costs to be spread over its duration; the restoration and post-operational management charges must instead be set aside progressively in a provision, not charged in full at closure. The horizon is not short: for landfills, the guarantee covering post-closure management must be maintained for at least thirty years from the closure notice, and the costs to be covered by the gate fee must be estimated over at least an equal period.
This is where many businesses in the sector misread their result for the year: if the restoration provision is not fed year after year, the profits of the years in which the plant is productive appear inflated and the charge arrives all at once at the end. The estimate must be updated at each reporting date on the basis of the volumes actually received. It should be borne in mind, however, that recognition in the accounts does not carry immediate deductibility with it: the TUIR does not allow provisions other than those expressly provided for, and the practice of the Agenzia delle entrate (the Italian tax authority) is not settled, with rulings pointing in different directions depending on whether the item is characterised as an atypical provision or as an accrual-based cost. In most cases the difference translates into an upward adjustment in the tax return and into the recognition of deferred tax assets: a point to be examined and documented beforehand, not during an audit.
References: art. 2424-bis, terzo comma, of the Italian civil code; accounting standard OIC 31 on provisions for risks and charges; art. 107, comma 4, of d.P.R. 917/1986; art. 208 of d.lgs. 3 aprile 2006, n. 152 for the single permit and the financial guarantees; art. 14 of d.lgs. 13 gennaio 2003, n. 36 for the guarantee on the post-closure management of landfills; rulings of the Agenzia delle entrate n. 272 of 2022 and n. 64 of 2023, which do not point the same way.
Revenue and VAT
When the treated aggregate ceases to be waste and becomes a product, the sale of the aggregate is a supply of goods and bears the standard VAT rate. Before that moment one is dealing with supplies of services, for which the rate depends on the type of operation. End-of-waste status, moreover, is not an accounting choice: it depends on compliance with the criteria set by the regulation on construction and demolition aggregates or, failing that, on the permit issued case by case.
In practice, consideration of different kinds coexists on the same invoice: acceptance of the waste, treatment, transport, sale of the recycled aggregate. Keeping them separate is not formalism. From 1° gennaio 2025, landfilling and incineration without efficient energy recovery have left the reduced rate and bear the standard one, while the other services of waste management, storage and temporary deposit remain at 10 per cent; metal scrap separated at the plant is treated on its own, as the reverse charge applies to it. Distinguishing the items avoids disputes on the VAT front and on the revenue front, and makes the real margin of each activity readable.
References: artt. 2, 3 and 6 of d.P.R. 26 ottobre 1972, n. 633; n. 127-sexiesdecies of Tabella A, parte III, annexed to the same decree, as amended by art. 1, comma 49, of legge 30 dicembre 2024, n. 207; art. 74, commi 7 and 8, of d.P.R. 633/1972 for scrap; art. 184-ter of d.lgs. 3 aprile 2006, n. 152 and d.m. Ambiente 28 giugno 2024, n. 127, which replaced d.m. 152/2022, on the end-of-waste status of construction and demolition aggregates.
Four stages, each with decisions that cannot be recovered afterwards.
Checking the requirements and the time window of the incentive — investments from 1° gennaio 2026 to 30 settembre 2028 — the form of the contract and the timing of delivery relative to the financial year.
Separation of the components, handling of advance payments and ancillary charges, documentation and electronic filings required for the incentive.
Interconnection and sworn appraisal. Book depreciation runs from entry into operation, the tax uplift only once the investment is completed and interconnected: they are two dates, and they must be kept distinct. The first allocation to the restoration provision is also recognised here.
Updating the estimate of future charges on actual volumes, managing deferred tax assets and checking that the incentive requirements continue to be met.
Environmental and civil works businesses have genuine industrial accounting, with job orders, plants and permit obligations that are reflected in the financial statements. Knowing the production cycle — what comes in as waste, what goes out as product, which safeguards the permit imposes — makes it possible to set up the accounts so that the numbers tell the real margin of each activity, and not just the overall result.
Studio PonchioSTP