Italy tax assessment: judicial rulings and redditometro updates

Recent legal and regulatory developments in Italy have clarified the mechanisms of tax assessment and the evaluation of evidence in tax litigation. According to a ruling by the Court of Cassation (n. 10807/2026), judges in tax proceedings possess the authority to evaluate evidence, including documents and 'atti notori', through prudent assessment, provided they adequately motivate their decisions. However, the burden of proof remains with the tax authorities to demonstrate the violations that form the basis of a tax assessment.

Parallel to these judicial clarifications, the 'redditometro'—a synthetic assessment tool used by the Agenzia delle Entrate to estimate real income based on a taxpayer's spending capacity and lifestyle—remains a significant point of focus. While recent data from the Corte dei Conti indicates a slight increase in the number of controls conducted via this method, the actual revenue collected through this channel has seen a decline. Current regulations, including Legislative Decree 108/2024, define the spending thresholds that trigger these assessments and establish the right to a preventive contradictory process, allowing taxpayers to provide counter-evidence to defend their declared income.