I motivi aggiunti nel processo tributario alla prova delle modifiche introdotte dalla riforma fiscale

The article analyzes the regulation of the expansion of grounds for appeal in tax process, through the introduction of so-called “additional grounds”, as already provided for by Article 24 of Legislative Decree 546/1992 and as introduced in the tax reform with the new Article 47-ter, concerning the definition of the judgment with a simplified judgment following the precautionary protection and the revised Article 58, for the appeal process. These new provisions, which build upon those established by Legislative Decree 104/2010, are integrated into the tax process, albeit not without challenges. They require interpret-ers to adopt a coordinated approach in light of the existing provisions of tax law, which remains distinct from administrative law.