The Constitutional Principle of Tax Cooperation Introduced by Amendment n. 132/2023

Abstract

The purpose of this study is to discuss the way in which the tax authorities and the taxpayer interact in a tax system characterized predominantly by a relationship of subordination and not by a relationship of mutual cooperation. The discussion on the various cooperative plans, with emphasis on the administrative procedural systematics, reveals the need to correlate the new perspective of procedural cooperation, introduced by the Code of Civil Procedure, with the traditional model of the fiscal administrative procedure. In addition to the procedural relationship itself, the analysis of the issue of tax cooperation and the limits of liability and punitive sanctions imposed on the taxpayer gains relevance.