New, partial, amnesty coming soon. The implementing decree of the fiscal delegation presented to the Council of Ministers provides the “facilitated settlement of all pending disputes”. A strengthening of the conciliation of disputes is therefore expected, extending its application in the Supreme Court (an option not currently foreseen) to which is added the abolition of mediation for disputes up to 50 thousand euros. For the first case there are at least 100 thousand proceedings pending in the Tax Commissions and in the Court of Cassation, with a value of approximately 40 billion euros. In these hours, the Deputy Minister of Economy Maurizio Leo, presenting the decree, said: “We had to somehow bring order to this matter, we do so by pushing hard on digitalisation and introducing a series of measures to the benefit of taxpayers”.
The new mechanism for closing disputes
In more than a year of government there have been over 12 amnesties. But how will the new mechanism work? Given the intention to computerize the tax process, greater use of communications via certified e-mail and remote hearing is expected, but details are still missing on the extent of the measure. The application of the changes is expected to start from January 2024 but, after the first passage in the Council of Ministers, the text will have to be submitted to Parliament for final approval.
It should be remembered that the facilitated definition provided for by the 2023 Budget, which concerns disputes attributed to the tax jurisdiction in which the Revenue Agency and the Customs Agency are part, pending in every state and level of the proceedings, including that pending at the Court of cassation and also following postponement, as of the entry date of 1 January 2023, it allowed approximately 7 thousand tax actions to be closed. But the topic is new disputes: as said by Deputy Minister Leo, there are 10,000 new cases a year.
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