Il contraddittorio endoprocedimentale nella legge delega per la riforma fiscale

The Parliament, in the context of the tax reform, recently approved by the Delegated Law (Law No. 111 of 9 August 2023), has highlighted the need for an organic intervention on the issue of procedural cross-examination. In fact, despite its unquestionable importance - especially in view of the highly authoritative nature of the activities of the tax authorities, traditionally focused on the control of taxpayers' obligations and on the fight against tax evasion - the matter has never been the subject of a general provision providing for its application for every type of tax and for every method of assessment, and uniformly regulating the procedures for its implementation and the consequences in the event of failure to do so.