Tax Litigation and Representation
We provide assistance in tax disputes — responding to assessment notices, filing appeals — representing clients before the competent authorities, in collaboration with qualified professionals.
Service details
When a taxpayer receives an assessment notice, an irregularity communication or a tax act from the Revenue Agency or the Collection Agent, it is essential to react promptly and competently. Studio CITI snc offers comprehensive assistance in tax litigation matters, in collaboration with trusted tax lawyers.
The process begins with analysing the received document: assessment notice, informal notice, payment order, INPS debit notice. Each act has specific response deadlines and appeal options, and incorrect analysis of the deadlines can definitively preclude the possibility of mounting a defence.
When facing an assessment notice, the main options are: agreed settlement (a deflationary procedure that allows the assessed amount to be reduced through a discussion with the Tax Office), mandatory tax mediation for disputes under 50,000 euros, and appeal to the Tax Court of Justice (formerly Tax Commission) for higher-value disputes. The firm evaluates with the client the most advantageous course of action in terms of probability of success and costs.
For payment orders and debit notices, it is possible to request instalment payment of the debt (up to 72 ordinary instalments, or 120 instalments in cases of proven financial hardship), remission in cases of error, or appeal within the legal deadlines. The firm manages all these procedures on behalf of the client.
Frequently asked questions
I received an assessment notice: by when must I respond? +
The deadlines depend on the type of act. For assessment notices, you have 60 days to submit a request for agreed settlement (which suspends the appeal deadline for a further 90 days) or to file a direct appeal with the Tax Court of Justice. For payment orders, the deadline for appeal is 60 days from notification. It is essential not to let these deadlines pass, as the act becomes final.
What is agreed settlement and is it worth doing? +
Agreed settlement is a procedure that allows the taxpayer to discuss the tax claims with the Revenue Agency and reach an agreement, benefiting from a reduction of penalties to one-third. It is advantageous when the Agency's claim is partially well-founded, or when the costs and uncertainties of litigation are high. The firm analyses the cost-benefit ratio to advise you on the optimal strategy.
Can I pay a tax collection order in instalments? +
Yes. It is possible to request instalment payment from the Collection Agent (Agenzia delle Entrate Riscossione) of up to 72 monthly instalments without needing to document financial hardship for amounts up to 120,000 euros. For higher amounts or for instalments up to 120, it is necessary to demonstrate temporary objective financial difficulty. The firm prepares the necessary documentation and submits the request on behalf of the client.
Also serving
Need this service?
Contact us to discuss your needs. We will provide a clear, tailored quote.
