Tax amnesty, criminal shield and the new timing

With the Law Decree no. 34 of March 30, 2023 (so-called “bill Decree”, hereinafter “LD 34/2023”) – published on the same date in the Official Journal and in force since March 31st, 2023 – some measures of the regime relating to the tax amnesty introduced by the Law of December 29th, 2022, no. 197 (i.e. the Budget Law for 2023) have been extended and innovated, also in relation to the tax crimes.

The criminal shield

One of the main new measures of the LD no. 34/2023 is represented by the introduction, in favor of those who apply for the tax amnesty, of a special cause of non-punishment of the following tax crimes: the crime of omitted payment of withholding taxes (article 10-bis of the Legislative Decree no. 74/2000), the crime of omitted payment of VAT (i.e. article 10-ter of the Legislative Decree no. 74/2000) and the crime of unlawful compensation of undue credits (i.e. article 10-quater, paragraph 1 of the Legislative Decree no. 74/2000).

Source PwC

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