- The company [ALFA] from Germany is seeking clarification on the applicability of the “ravvedimento speciale” (special remedy) for late submission of group VAT liquidation guarantees.
- They intend to submit late guarantees for the years 2019, 2020, and 2021.
- The company plans to regularize their position through the “ravvedimento operoso” (active remedy) by submitting guarantees and paying the corresponding penalty.
- They are asking if they can apply the “ravvedimento speciale” for the mentioned tax years.
- The company believes that the “ravvedimento speciale” can be used for violations related to declarations, including incorrect invoicing or improper deduction.
- They refer to Article 21 of decree-law 34/2023, which states that the “ravvedimento speciale” can be used to resolve violations under Article 13 of legislative decree 472/1997 for the tax period ending on December 31, 2021, and previous tax periods.
Source: agenziaentrate.gov.it
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
