Tax Litigation · Bologna
Tax Litigation for clients in Bologna
Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance in Bologna.
Representation before the Tax Courts (Corti di Giustizia Tributaria) and the Italian Supreme Court (Corte di Cassazione). Dedicated assistance for clients in Bologna e Emilia-Romagna, managed entirely through the electronic tax court filing system (PTT) from the Firm's office in Rome.
In Brief
The Firm Marzo Associati offers specialist assistance in tax litigation to businesses and taxpayers in Bologna e Emilia-Romagna. The service is structured for clients in the area: Motor Valley, packaging, biomedical industries, precision engineering, agri-food and cooperatives.
What Is tax litigation and When Is It Needed
Tax litigation is the procedure through which taxpayers challenge acts issued by the tax authorities and tax collection bodies before the Tax Courts (Corti di Giustizia Tributaria), under D.Lgs. 546/1992 as amended by Legge 130/2022 and D.Lgs. 220/2023. Appealable acts include tax assessment notices, penalty notices, tax payment notices (cartelle), demands for payment, administrative vehicle seizures (fermo amministrativo) and tax mortgage registrations (ipoteca). As a rule, an appeal must be brought within 60 days of service of the act.
Tax Defence and Representation
We regularly represent companies (resident and non-resident), entities and individuals at every stage and level of tax proceedings. The aim is to uphold the Taxpayer's case in the name of the right to fair taxation.
Areas of Practice
- Proceedings on the Merits: Assistance before the Tax Courts (Corti di Giustizia Tributaria) of first and second instance.
- Review on Points of Law: Representation before the Italian Supreme Court (Corte di Cassazione) and EU judicial bodies dealing with tax matters.
- Precontenzioso: Managing relations with the tax authorities during tax audits, on-site visits and inspections, including the tax settlement procedure (accertamento con adesione) stage to prevent litigation.
- Riscossione: Protection against tax payment notices (cartelle) and precautionary measures (tax mortgages (ipoteche), administrative vehicle seizures (fermi amministrativi)).
Tax Court (Corte di Giustizia Tributaria) of First Instance in Bologna
Via Marco Polo 60 — 40131 Bologna
The Tax Court (Corte di Giustizia Tributaria) of second instance for Emilia-Romagna is based in Bologna and hears appeals from all provinces of Emilia-Romagna (Modena, Reggio Emilia, Parma, Piacenza, Ferrara, Ravenna, Forlì-Cesena, Rimini).
How the Procedure Works for Clients in Bologna
- 1
Review of the Act and Time Limits
Verification of service, the statement of reasons, statutory time bars and the suspension of time limits during the court summer recess.
- 2
Choosing a Defence Strategy
Assessment of the options: a self-correction request (autotutela), the tax settlement procedure (accertamento con adesione), which suspends time limits for 90 days, or a direct appeal.
- 3
Electronic Filing of the Appeal
Service by certified email (PEC) and entry of appearance through the electronic tax court filing system (PTT), with an application to suspend the contested measure under art. 47 D.Lgs. 546/1992 where appropriate.
- 4
Hearings and Subsequent Appeals
Oral submissions before the Tax Court (Corte di Giustizia Tributaria) of first instance, appeals to the Tax Court (Corte di Giustizia Tributaria) of second instance and, where the conditions are met, appeals to the Italian Supreme Court (Corte di Cassazione).
Documents are filed electronically with the Tax Court (Corte di Giustizia Tributaria) of First Instance in Bologna (Via Marco Polo 60, 40131 Bologna); hearings may take place remotely or in person, depending on the requirements of the defence.
Common Cases in Bologna e in Emilia-Romagna
IVA intracomunitaria e cessioni UE
Defence against allegations of non-existent transactions, evidence of intra-EU supplies, and correct application of VAT exemption regimes.
Crediti d'imposta R&S e Industria 4.0
Disputes over technology tax credits challenged as non-existent, sworn expert reports and classification of activities.
Transfer Pricing in Motor Valley and Packaging Groups
Defence of transfer pricing documentation, master files and country files for groups with foreign subsidiaries.
Taxation of Cooperative Companies
Disputes concerning the application of preferential regimes under L. 904/1977, indivisible reserves and predominantly mutual status.
Agri-Food Taxation and PDO/PGI
IVA, IRAP e tributi indiretti nelle filiere produttive emiliane (Parmigiano, prosciutto, aceto balsamico, vini).
The Firm also assists clients in neighbouring provinces: Modena, Reggio Emilia, Parma, Ferrara, Ravenna, Forlì-Cesena, Rimini, Piacenza.
Documents to Gather and Timeframes
- —Contested measure together with the certificate of service
- —Tax audit report and any questionnaires
- —Tax returns and financial statements for the tax periods under dispute
- —Supporting accounting and contractual documentation
- —Previous applications, written submissions or correspondence with the tax office
The standard deadline for an appeal is 60 days from service, extended where an application for the tax settlement procedure (accertamento con adesione) is submitted or the summer suspension of procedural time limits (1–31 August) applies. The Court deals with applications for interim relief promptly; the time required to conclude first-instance proceedings varies according to the court's caseload.
For an assessment of your position, you can or consult the profile of the Firm's tax lawyers.
How We Handle tax litigation for Clients in Bologna
Confidential Video Consultation
Riunioni strategiche su Google Meet o Microsoft Teams.
Digital Power of Attorney
Appointment using a qualified electronic signature.
Hearings Before the Tax Court (Corte di Giustizia Tributaria) of Bologna
Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.
Targeted Visits
Site visits in Bologna only when essential.
Professionals Responsible for the Service
Frequently Asked Questions
Do You Need Assistance With tax litigation a Bologna?
Open a confidential case file with our team. Response within 24 hours.