With the circular no. 122 of 22 October, signed by the general manager, Gabriella Di Michele, INPS has provided indications on the scope of operation of the contribution relief called "South decontribution” provided for by the August decree, converted into Law 13 October 2020, n. 126. In order to contain the extraordinary effects on employment caused by the Covid-19 epidemic in areas characterized by serious situations of socio-economic hardship and to guarantee the protection of employment levels, the subsidy, without prejudice to the calculation of pension benefits, consists ofexemption of 30 per cent of the social security contributions payable by private employers (excluding the agricultural sector and domestic work), net of premiums and contributions due to Inail, for the period from 1 October to 31 December of this year, with reference to the employment relationships (already established and in the process of being established) whose place of work, at which the employees concerned are actually reported, is located in the regions of Abruzzo, Basilicata, Calabria, Campania, Molise, Puglia, Sicily and Sardinia.
The law does not provide for an individual limit on the amount of the exemption. Therefore, the relief is applied to 30% of the employer's contribution without a monthly cap. The benefit, not having the nature of an incentive to hire, is not subject to the application of the general principles on employment incentives, while it is subject to the possession of the Single Document of Contribution Regularity (Durc), without prejudice to the absence of violations of the fundamental laws protecting the conditions of work and compliance with other legal obligations and with the collective labor agreements and contracts signed by the most representative trade union organizations of workers and employers at national level (see in this regard the indications of the National Labor Inspectorate).
The subsidy can also be combined with other exemptions or reductions in loan rates provided for by current legislation within the limits of the social security contribution due. Finally, the contributory benefit, as it is aimed at a specific audience of recipients (employers operating in disadvantaged areas), is configured as a selective measure which, as such, requires the prior authorization of the European Commission. For this reason, the Ministry of Labor and Social Policies notified the State aid scheme to the European Commission on 30 September 2020 and the aid was approved with decision C (2020) 6959 final of 6 October.
It is recalled that the European Commission considers state aid compatible with the internal market if it complies, among others, with the following conditions:
• are of an amount not exceeding 800.000 (per company and gross of any tax or other charge);
• are granted to companies that were not in difficulty as at 31 December 2019 or that have encountered difficulties or have found themselves in a situation of difficulty subsequently, following the Covid-19 epidemic;
• are granted by 30 June 2021.
It is emphasized that employers interested in using the benefit will have to display, starting from the Uniemens flow pertaining to October 2020, the workers for whom the facilitation is due.
