The structural aspects of the two-year preventive agreement are examined, in the light of the changes brought by the corrective decrees, and a composite rationale is discussed. It marks a new way of implementing the tax duty, by pre-determining its amount through statistical-mathematical methodologies. Thus, it favours simplification and ex ante certainty of the tax as opposed to the precise measurement of incomes yet difficult to be assessed a posteriori. Tampering the tax duty creates strains, inter alia, with the rule of law.
PROFILI DEL NUOVO CONCORDATO PREVENTIVO, RAPPORTI CON L’ACCERTAMENTO E CON LA RISERVA DI LEGGE
CANE' D
2025-01-01
Abstract
The structural aspects of the two-year preventive agreement are examined, in the light of the changes brought by the corrective decrees, and a composite rationale is discussed. It marks a new way of implementing the tax duty, by pre-determining its amount through statistical-mathematical methodologies. Thus, it favours simplification and ex ante certainty of the tax as opposed to the precise measurement of incomes yet difficult to be assessed a posteriori. Tampering the tax duty creates strains, inter alia, with the rule of law.
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