The Italian Revenue Agency (IRA) has published Provision (Prot.) no. 356446/2022 of 16 September 2022 for the implementation of Article 5 of Law No. 130 of 31 August 2022 on provisions for tax justice. Under Article 5, pending tax disputes before the Supreme Court may be settled through the payment of a percentage of the disputed amount, net of interest, default penalties, etc. as follows:
- 5% if the net amount does not exceed EUR 100,000 and the IRA has been unsuccessful in all previous stages of the dispute (i.e., the taxpayer won in all lower courts); and
- 20% if the net amount does not exceed EUR 50,000 and the IRA was partially unsuccessful (i.e., the taxpayer won in at least one lower court).
Source Orbitax
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