Institutional portal - Municipality of Milan

Definable acts
The new definition refers to tax disputes pending, in every state and level of the judgement, including that in Cassation and also following referral, whose introductory appeal has been notified to the Municipality regarding ici, imu, tasi, tarsu, tares , tari, icp, tourist tax by 1 January 2023.

Non-definable acts
The facilitated definition is not permitted for disputes relating to refusals of reimbursement, express or tacit.

With reference to the date of January 1, 2023, the following is due: 

• 100% of the value of the dispute if:
  - the appeal notified to the Municipality of Milan has not yet been filed with the Tax Court of Justice
  - the latest non-precautionary ruling filed is in favor of the Municipality of Milan
• 90% of the value of the dispute in the event of an appeal registered in the first instance or pending the referral proceedings ordered by the Court of Cassation
• 40% of the value of the dispute if a first degree ruling, other than the precautionary one, unfavorable to the Municipality of Milan had been filed
• 15% of the value of the dispute if a second degree ruling, other than the precautionary one, unfavorable to the Municipality had been filed.
• 5% of the value of the dispute in the event of disputes pending before the Court of Cassation for which the Municipality of Milan has been unsuccessful in all previous levels of judgement.

In case of mutual defeat it is due, on the value of the dispute: 

• 100% relating to the share recognized as due to the Municipality of Milan;
• 40% relating to the portion recognized as not due, if the last non-precautionary ruling filed is of first instance; 
• 15% relating to the portion recognized as not due, if the last non-precautionary ruling filed is of second degree

For the settlement of disputes relating exclusively to sanctions not connected to the tax, the following amounts are due:

• 15% of the value of the dispute if the Municipality of Milan was unsuccessful in the last or only non-precautionary ruling filed by 1 January 2023
• 40% of the value of the dispute in all other cases

In case of partial defeat, the following is due with respect to the value of the dispute:

• 15% for the part in which the Municipality of Milan was unsuccessful
• 40% for the remaining part

Il value of the dispute is given by the amount of the tax which was contested at first instance, net of interest, late payment compensation and any sanctions linked to the tax, however imposed. In the event of disputes relating to the imposition of sanctions, the value of the dispute is given by the amount of the sanctions.

Separation of amounts already paid
Paragraph 196 of the art. 1 of law no. 197/2022 provides for the separation from the amounts due, on the basis of the percentages reported above, of the amount already paid "for any reason" pending judgment, without prejudice to the fact that the definition does not in any case give rise to the refund of the sums paid, but in excess of what is due based on the definition.

For disputes up to 1.000 euros the entire amount must be paid by September 30, 2023.

For disputes exceeding 1.000 euros it is possible to do:
- full payment by 30 September 2023
- payment in installments, paying the first installment by 30 September 2023

Installment method

The amount of first payment will be established in relation to the number of installments chosen, with a maximum of twenty installments.
for installments subsequent to the first, interest is expected to be applied, calculated at the legal rate, starting from 1 October 2023.

The calendar of deadlines following the first is as follows:

• 31 October 2023
• 20 December 2023

Starting from 2024 and for each subsequent year:

• 31 March
• 30nd June
• September 30th
• 20th December

Alternatively, at the taxpayer's choice, starting from January 2024, the installments following the first three may be paid in a maximum number of 51 monthly installments of the same amount, expiring on the last working day of each month. Only for the month of December the payment deadline will be the 20th.

Payment
For the payment of ici, imu, tasi, tarsu, tares, tari you can use the model F24, filling in the section dedicated to payments for local taxes with the relevant tax codes.

The advertising tax it must instead be paid by bank transfer to IBAN IT18E0306901783100000000351

Nonpayment
In the event that the indicated deadlines are not respected, the Municipality of Milan will proceed to compulsorily recover the amounts due and not paid, applying the sanctions provided for in Article 15ter of Presidential Decree 602/1973.