Tax Debt Restructuring · Naples
Tax Debt Restructuring for clients in Naples
Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance in Naples.
Tax settlements and insolvency proceedings. Dedicated assistance for clients in Naples e Campania, 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 debt restructuring to businesses and taxpayers in Naples e Campania. The service is structured for clients in the area: business disputes involving SMEs (restaurants, accommodation, construction, agri-food), a substantial volume of litigation concerning enforced collection, local taxes (municipal property tax (IMU), TARI) and assessments relating to tourism and property activities.
What Is tax debt restructuring and When Is It Needed
Tax debt restructuring involves managing liabilities to the Italian Revenue Agency (Agenzia delle Entrate) and the Italian Tax Collection Agency (ADER): instalment plans, tax settlements within preventive composition proceedings and restructuring agreements (artt. 63 e 88 del Codice della crisi, D.Lgs. 14/2019), negotiated settlements and over-indebtedness procedures. The aim is to ensure that the plan is sustainable and the business can continue operating.
Business Insolvency Management
We support businesses in financial difficulty through the tools provided by the Business Insolvency Code, with a specific focus on renegotiating tax debt.
Tools Used
- Tax Settlement: Negotiations with the Italian Revenue Agency (Agenzia delle Entrate) to reduce tax debt and extend payment terms (Art. 182-ter L.F. / Codice della Crisi).
- Restructuring Agreements: Assistance in drafting court-approved recovery plans.
- Rottamazione e Definizione Agevolata: Assessment of the opportunities offered by "tax truces" to reduce penalties and interest.
- Sovraindebitamento: Procedures for managing the financial distress of persons and entities not subject to bankruptcy proceedings and of professionals.
Tax Court (Corte di Giustizia Tributaria) of First Instance in Naples
Via dei Tribunali 224 (Castel Capuano) — 80138 Naples
Historic premises in the Castel Capuano complex. One of the Italian courts with the highest volumes of pending litigation. The Tax Court (Corte di Giustizia Tributaria) of second instance for Campania is based in the same city.
How the Procedure Works for Clients in Naples
- 1
Debt Snapshot
Extract from the collection register and detailed breakdown of taxes, penalties, interest and collection fees, with checks on limitation periods.
- 2
Choice of Instrument
Comparison of ordinary or extraordinary instalment plans, negotiated settlements, restructuring agreements and composition proceedings.
- 3
Preparing the Proposal
Preparation of the plan and the report on its advantages over judicial liquidation.
- 4
Negotiations and Court Approval
Negotiations with the relevant offices, filing of the tax settlement proposal and management of the court approval stage.
Documents are filed electronically with the Tax Court (Corte di Giustizia Tributaria) of First Instance in Naples (Via dei Tribunali 224 (Castel Capuano), 80138 Naples); hearings may take place remotely or in person, depending on the requirements of the defence.
Common Cases in Naples e in Campania
Analytical and Presumptive Tax Assessments of SMEs
Defence against sector studies, ISA, assessments based on the redditometro and the availability of assets indicating ability to pay tax.
Enforced Collection Litigation
Challenges to tax payment notices (cartella), demands for payment, administrative vehicle seizures (fermo amministrativo) and tax mortgages (ipoteca) imposed by the Italian Tax Collection Agency (ADER).
IVA nei settori ricettivo e ristorazione
Contestazioni su aliquote ridotte, regime forfettario, fatturazione elettronica e corrispettivi telematici.
Local Taxes and Municipal Property Tax (IMU)/TARI Litigation
Appeals against tax assessments issued by municipalities in the province of Naples concerning properties, accommodation businesses and waste generation.
Construction, Public Procurement and Sector-Specific Taxation
Defence against claims concerning VAT, withholding taxes, social security contributions and joint and several liability in construction contracts.
The Firm also assists clients in neighbouring provinces: Caserta, Salerno, Avellino, Benevento.
Documents to Gather and Timeframes
- —Up-to-date Extract from the Collection Register
- —Tax Payment Notices (cartella), Demands for Payment and Administrative Vehicle Seizure (fermo amministrativo) or Tax Mortgage (ipoteca) Orders
- —Bilanci e situazione economico-patrimoniale aggiornata
- —Business and Financial Plan
- —List of Creditors and Existing Security
Ordinary instalment plans are processed promptly by the collection agent; insolvency resolution procedures follow the time limits set by the Insolvency Code, with their duration depending on the complexity of the plan and the number of creditors.
For an assessment of your position, you can or consult the profile of the Firm's tax lawyers.
How We Handle tax debt restructuring for Clients in Naples
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 Naples
Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.
Targeted Visits
Visits to Naples only when essential.
Professionals Responsible for the Service
Frequently Asked Questions
Do You Need Assistance With tax debt restructuring a Naples?
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