The tax dispute is a judicial proceeding concerning the tax disputes between the tax payer and the tax authorities.
Tax litigation is a judicial proceeding concerning disputes
of a tax nature between the tax payer and the financial administration.
It is currently regulated by the legislative decree n. 546 of 31 December, which, in article 1, paragraph 2, states that:
«The tax courts apply the provisions of this decree and, as far as they are not disposed and compatible with them, the rules of the code of civil procedure»
The subject of the trial are administrative deeds of the financial administration, challenged by the tax payer. It is known that the administration can issue binding acts for the tax payer, if not timely challenged, without having to resort to the judicial authority.
