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Corrective decree on tax compliance
Monday 28 April 2025

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Confindustria intervened, by sending a memorandum, during the examination by the Finance Committees of the Chamber of Deputies and the Senate, called to give an opinion on the legislative decree outline containing supplementary and corrective provisions on tax compliance, two-year composition agreement, tax litigation and tax penalties (approved by the CDM on 13 March 2025).

In particular, the Confindustria intervention contains considerations and proposals for changes in the area of customs reform and facilitated definition of sanctions taxation and coordination rules. As far as customs reform is concerned, the remarks focus on the Contraband for false declarationof the Administrative Penalties and Extinction of Contraband Offences Punishable by Fine Only.

The plea dwells on a question concerning to the new penalty provision, for intra-Community suppliesintroduced by the so-called 'Sanctions' decree, calling for a regulatory change. The rule, in fact, introduces a peremptory deadline of 90 days for companies that do not wish to incur further sanctions to fulfil new obligations. This is an inadequate deadline, not least because of the operational complexities involved in finding suitable evidence.

A further profile of interest, which finds no positive explication neither in the delegated decree nor in the corrective under consideration, is the figure of the Authorised Economic Operator (AEO), which voluntarily submits itself to a customs authority comparison and audit procedure, thus making it a reliable partner and which, as is the case throughout Europe, should be promoted and supported.

A final institute in need of further amendment and affecting several provisions is that of the confiscation.

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