RAVVEDIMENTO 2.0, TRA DEFLAZIONE DEL CONTENZIOSO, FISCALITÀ NEGOZIATA E CRIPTO-CONDONISMO. PRIME NOTE

The Stability Law for 2015 has greatly expanded the possibilities for applying the Repentance (Ravvedimento”), to regularize the committed tax violations with a limited burden of penalties, to admit - albeit with limitations - the possibility to define violations emerged after tax checks. The article examines the changes in-troduced with reference to the system of deflationary litigation figures, highlighting gaps and weaknesses of the introduced innovations.