Italian Supreme Court narrows tax enforcement tools in two key rulings

The Italian Supreme Court issued two rulings that reshape tax‑collection procedures. In the first, the Court interpreted the provisions governing a seizure of third parties by the Agency for Tax Collection (AdER) to automatically cease effectiveness after 60 days from notification. Any funds paid by the third party after that period must be returned to the taxpayer, and extending the seizure beyond 60 days requires a separate ordinary court procedure.

In the second ruling, the Court held that bank‑account investigations must be preceded by a preventive, specific and verifiable authorization. Without such authorization, the obtained banking data are unusable and any tax assessment based on them is invalid. Both decisions tighten procedural safeguards for taxpayers and set clearer limits on the tax authority’s investigative powers.