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Tax Pills

“Cure Italy” Decree: the stop of tax deadlines also extended to fiscal verifications with acceptance


The suspension of time limits, decided by the Government, will also apply to fiscal assessments with adhesion. In fact, even this particular tax enforcement instrument is included among the fiscal postponements provided by the “Cure Italy” Decree, respectively within articles 67 and 83. In addition to restating this point, with the publication of Circular n. 6 Italy’s Revenue Agency has also intended to clarify that the taxpayers concerned can still ask the offices to finalize the verifications with acceptance even during the suspended period, provided this does not conflict with the protection of public health.

Space for innovative telematics procedures – This choice, which is optional, is made possible thanks to the opportunity of making a cross-examine fiscal procedure, the so-called “contraddittorio”, also by telephone or video conference, with subsequent exchange and signature of the minutes through certified or even ordinary e-mail. Furthermore, as announced with the press release of 12 March 2020, the Director of the Revenue Agency, Ernesto Maria Ruffini, has also given instructions to the offices to suspend the activities of assessment and litigation, verification, access, inspection and liquidation, with the exclusion of procedural acts and activities deemed not postponable.

How the suspension works - According to the Agency, article 83 of the “Cura Italy” Decree which provides for the suspension of the terms for litigation also applies to the tax verification procedure submitted by the taxpayer. Therefore, the suspension of the 90-day term (paragraph 3 of article 6 of Legislative Decree no. 218 of 1997) and the suspension provided for by article 83 of the decree apply cumulatively to the appeal period. For example, in the case of a notice of assessment notified on January 21, 2020 and a request by a taxpayer for a verification with acceptance submitted on February 20, 2020, the deadline for signing the act of assessment with adhesion will expire on July 27, 2020.

Adhesion possible even at the time of Coronavirus - In case of concrete and shared interest, it is still possible to carry out the verification procedure with acceptance, but avoiding physical contacts and travel. In these cases, the fiscal cross-examination can take place "remotely", favoring the use of certified e-mail and using the telephone or any video conferencing tool. The Circular explains which are the steps taxpayers need to follow to open this innovative channel with the Revenue Agency.

Stefano Latini