Covid-19: New deadlines for tax audits in Italy

published on 26 May 2020 | reading time approx. 2 minutes

by Luca Schröder

Covid-19 had and is still having a wide impact all over the world and Italy is no exception. One of the main effects, from a fiscal perspective, is given by the shift of tax relevant deadlines, especially the postponement of the terms during which tax audits on past years could be made

In general, by the end of 2020, 2015 and previous year should no longer be subjected to tax audits. However, the government has decided, through its latest Law Decree (“Relaunch Decree”), to postpone to 31 December 2021 the notifications of those verifications expiring between 9 March 2020 and 31 December 2020. This means that the Tax Authorities are still allowed to perform the tax audits within 2020 but that they are going to send the corresponding notifications during the year 2021. Under these circumstances, the taxpayers can not consider the year 2015 as being generally expired for the sake of tax audits in 2020 as they may still receive in 2021 the corresponding notifications.

Furthermore, the terms for other deflationary measures during tax audits saw the following modifications of deadlines for “notice of assessment” (i.e. “Avviso di Accertamento”, hereinafter also “AdA”) with “adhesion” (i.e. “Adesione”):

• Submitted before 8 October 2019: Conventional deadlines as it expired before 9 March 2020;
• Submitted starting from 9 October2019: deadline determined by adding to the 60 + 90 days period of time 64 additional days. Moreover the "summer suspension” has also eventually to be considered (i.e. approximately all of August).

Deadlines for AdA without “Adesione”:

• Submitted until 6 January 2020: conventional deadline to be determined by adding 60 days to the day of notification;
• Submitted after 07 January 2020: payments and appeal have been postponed to 16 September 2020 while, on the other hand, the deadline for sanctions still has to be determined by adding to the day of notice 60 + 64 days;
• Submitted after 9 March 2020: the 60 days time period starts from the 11 May 2020.

Further clarifications and modifications may arise as the Relaunch Decree has to be adopted through a conversion law that could confirm or further modify the provisions introduced by the described decree.