Italian tax judges split over tax settlement and notification rules

Italian tax judges are divided on whether a pre‑payment invitation to appear blocks the special settlement (ravvedimento speciale) linked to the biennial preventive agreement (CPB). One court in Verona ruled that a simple request for documents or an invitation to appear is sufficient to prevent the settlement, while a court in Sassari held that only a formal assessment notice can block it. The CPB allows taxpayers who join the 2024‑2025 agreement to regularise past years (2018‑2022) by paying a substitute tax, provided no prior act that the law identifies as obstructive is issued.

The Italian Supreme Court clarified that a preventive dialogue and a "bonary notice" are not required for automated tax assessments when the issue involves merely unpaid declared taxes and no significant uncertainties. In such cases, a tax notice (cartella) can be issued without prior communication, as long as the declaration shows no errors.

These rulings define the limits of preventive notifications and the protection offered by the CPB, affecting taxpayers and advisors navigating Italy’s tax settlement procedures.