Icp self-protection

The Administration can prevent disputes with the taxpayer by canceling, partially or totally, its actions vitiated by the presence of errors.

  • The cancellation is established by the same office that issued the document following a request for review presented by the taxpayer
  • the Administration will communicate the outcome of the request with the reasons for the decision taken
  • the presentation of the self-defense request does not prejudice or suspend the right to appeal.

The annulment of the illegitimate act can also be carried out if:

  • judgment is pending
  • the act has now become definitive due to the expiry of the deadlines for appeal, provided that the tax basis is totally or partially lacking
  • the taxpayer lodged an appeal and this was rejected for formal reasons (inadmissibility, inadmissibility, inadmissibility) with a final ruling, provided that the tax basis was totally or partially lacking.

The annulment of the illegitimate act automatically entails the annulment of the consequential acts (for example, the withdrawal of an unfounded assessment notice entails the annulment of the consequent registration in the register and the related executive titles) and the obligation to return of the sums collected on the basis of the annulled documents.

Updated: 16/04/2024