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Italian tax authority Burden of Proof in Property Valuation
Published: 2026/01/31 01:45:50
The Shifting Landscape of Tax Assessments
Recent rulings from Italy’s Cassazione (Court of Cassation) are clarifying the standards for the Italian tax authority (Agenzia delle Entrate) when challenging the declared value of property and businesses during a sale. These decisions significantly impact how tax assessments are conducted and the level of evidence required to justify adjustments to reported gains.
Legislative Framework: Decree Law 147/2015
The foundation for these changes lies in Article 5, paragraph 3, of Decree Law 147 of 2015. This legislation prevents the tax authority from
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