The tenor of the discipline of the so-called special repentance (Article 1, paras. 174 et seq., Law no. 197/2022) appears to allow its application to violations of failure to pay taxes exposed in tax returns, not detected by the Revenue Agency. However, administrative exegesis has excluded this hypothesis, with a solution endorsed by a provision (Article 21, par. 1, Law Decree no. 34/2023), qualified as “authentic interpretation”, which does not seem to have these features.
Ravvedimento speciale, “rilevabilità” degli illeciti tributari di omesso versamento e norme di (pseudo-)interpretazione autentica
Roberto Iaia
2023-01-01
Abstract
The tenor of the discipline of the so-called special repentance (Article 1, paras. 174 et seq., Law no. 197/2022) appears to allow its application to violations of failure to pay taxes exposed in tax returns, not detected by the Revenue Agency. However, administrative exegesis has excluded this hypothesis, with a solution endorsed by a provision (Article 21, par. 1, Law Decree no. 34/2023), qualified as “authentic interpretation”, which does not seem to have these features.
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