Historic turning point in tax assessments and fines, with a commitment to conduct a comprehensive pre-assessment inspection notice

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    Historic turning point in tax assessments and fines, with a commitment to conduct a comprehensive pre-assessment inspection notice

    What does the Hear Before Issuing Notice of Evaluation provide? Tax assessment rules are changing, and the government aims to establish a new relationship between tax authorities and taxpayers on the basis of “trust” in order to allow taxpayers to “not be afraid” of tax authorities and facilitate them in repaying debts and settling outstanding situations. And it is thanks to this novelty that discussions with taxpayers become mandatory. Let’s see what it is and what it changes.

    • Compulsory adversarial principle what it offers
    • How does adversarial compliance work for taxpayers?

    Compulsory adversarial principle what it offers

    The compulsory hearing principle is a step that allows the taxpayer to defend himself before receiving the Notice of Assessment from the Revenue Agency. It must be implemented by the revenue itself.

    As a result of the mandatory hearing principle, a taxpayer must be called into agency offices to explain his or her defense and provide explanations regarding any tax cases that are subject to assessments.

    So, The principle of a compulsory hearing must be applied before a Notice of Assessment is issued by the Revenue Agency and with reference to all tax assessments, regardless of the type of tax or local authority involved.

    In fact, the mandatory hearing principle has already been in effect since July 1, 2020, and so there is already an obligation for revenue agency offices to invite a taxpayer to a hearing before issuing assessment notices with respect to income and supplemental taxes, social security contributions, withholdings, alternative taxes, IRAP, Eva, Effie, Effie. However, it has now been extended to all types of tax assessments.

    How does adversarial compliance work for taxpayers?

    Given that, due to adherence to the contradictory principle, a revenue agency cannot issue notices of tax estimate without first calling the taxpayer to receive specific explanations, Taxpayers enjoy several advantages.

    The principle of compulsory listening In fact, taxpayers are allowed to defend themselves and to state their reasons for any improper situation beforehand, avoiding any subsequent disputes and appeals to a judge, while increasing costs.

    Another tax advantage that can derive from the compulsory listening principle is that of transparency and cooperation between the revenue agency and the taxpayer, as it aims to create and promote a dialogue based on mutual information and clarifications, just as the government has announced that it intends to do.

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