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Italy: Judicial proceedings in tax litigation, delayed deadlines in response to coronavirus (COVID-19)

Italy: Judicial proceedings in tax litigation

Measures introduced by Law Decree no. 11 (8 March 2020) are intended to address how Italy’s judicial system will function during the existing coronavirus (COVID-19) emergency. The measures in the law decree are designed to allow the judicial system and tax litigation to function while provisions are put into place to prevent the spread of the virus.


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The following measures are effective from 9 March to 22 March 2020.

  • Tax litigation hearings are generally postponed, except in certain instances when postponement could cause “serious damage” (e.g., hearings about the suspension of provisional tax collection).
  • Court deadlines are postponed (for instance, the deadline for submissions of documents).
  • Court fees must be paid electronically.

From 23 March to 31 May 2020, access to the courts may be restricted (by reducing public hours, requiring online or telephone bookings, etc.)

Moreover, certain tax courts have already introduced additional measures—such as postponing scheduled hearings until after 3 April 2020 and prohibiting representatives of taxpayers and the tax authorities from attending certain hearings.

KPMG observation

There is a question as to whether the subject postponements in fact suspend the deadline for seeking judicial review of tax assessments or the deadline for appealing a lower tax court decision. The goal of the postponements provided by the law decree is to prevent further spread of the coronavirus. Accordingly, some believe that the postponed deadlines only apply with regard to hearings that have been scheduled for the period between 9 March and 22 March 2020. Because there have been a series of decrees issued by the government in swift succession, potentially affected taxpayers need to consider their options including whether to wait for explicit rules or official clarifications defining the scope of application of the recent general suspension of the time limits.

Read a March 2020 report [PDF 157 KB] prepared by the KPMG member firm in Italy

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