Greater computerization and digitization of tax process documents, an enhancement of conciliation to clear the backlog of cases but also the possibility of remote hearings.
The rules for the implementation of the Litigation reform are coming with the aim of making procedures simpler and processes faster. In fact, the Council of Ministers has approved a delegated decree that implements the indications contained in the tax delegation.
Among the novelties is the possibility for companies to adhere to the so-called 'collaborative compliance' which allows the possible support of the Revenue Agency and certainty on payments and controls. This is provided for by one of the decrees implementing the tax delegation according to which the threshold for joining this regime, now set at one billion, will gradually fall to 750 million in the two-year period 2024-25, to 500 million in the two-year period 2026-27, to reduce 100 million euros from 2028.
The collaborative compliance aims "to establish a relationship of trust between the tax authorities and the taxpayer through constant and preventive dialogue with the taxpayer, assisted by highly qualified professionals, aimed at a preliminary assessment of the situations that generate tax risks".
The novelty provides greater control of tax risks for companies through the Tax Control Framework. Taxpayers, in order to join the regime, must be equipped with a system for detecting, measuring, managing and controlling tax risk (Tax Control Framework), certified by highly qualified professionals. The adoption of this certified control system, which is the basis of the collaborative compliance regime, will make it possible to identify in advance any transaction that may generate tax risks. Action will be taken ex ante rather than ex post in order to reduce litigation and ensure legal certainty.
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