The tax authorities and Italians are arguing less: appeals are down, but not for the IMU. Here’s why

New tax disputes are on the decline. In the first three months of 2026, just over 53,000 new cases were filed with the tax courts of first and second instance, representing a decrease of 8.1% compared with the first quarter of 2025. This downward trend confirms a pattern already evident in previous months. In fact, looking at the first instance alone, new disputes have actually fallen by 10.6% compared with the first three months of 2025 (whilst the second instance saw a slight increase: +0.6%). However, there is also a downward trend in the number of pending cases: those still awaiting a decision as at 31 March stood at around 235,000, representing a 12 per cent fall at first instance and a 3.8 per cent fall on appeal compared with the first quarter of 2025. These are some of the figures contained in the quarterly report by the Tax Justice Department, headed by Fiorenzo Sirianni.

The reduction applies to both central government and local taxes. As regards the former, ‘the most significant decreases in numerical terms relate to disputes concerning personal income tax (IRPEF) and VAT’. Particularly with regard to direct taxes – although this is not mentioned in the report – the changes introduced through the implementation of the tax delegation law have had an effect in reducing the number of new disputes; in particular, the preliminary hearing and the introduction of the draft decision should be noted.

With regard to local taxes, the Department of Tax Justice notes that ‘against a backdrop of a general decline, there has been a counter-trend, with an increase in appeals concerning property taxes’. In fact, there has been an increase in litigation, particularly regarding the IMU property tax, whilst – as the report itself explains – there has been a significant decrease in cases relating to waste disposal (+26%) as well as vehicle taxes and duties (-31.8%).

The reasons may also be linked to appeals that ‘follow’ the audit trends of local authorities, which may have focused more heavily on property-related taxes.

The figures for the first quarter of 2026 – as noted by the department – show ‘a predominance of new first-instance litigation concerning central government taxes in the tax courts of the North-East and North-West, whilst local taxes predominate in the Centre and South’. At second-instance level, ‘disputes concerning central government taxes predominate across all regions of the country’.