Italians in dispute with the tax authorities for 23 billion euros. VAT the most contested tax but offices win in 57% of cases
Tax litigation down 6.2% but value of cases remains high. The podium of cases is still taken by the unified contribution. Administration offices win 4 out of 5 disputes
by Marco Mobili
4' min read
Key points
4' min read
Taxes may be nice, but nobody really likes paying them. In addition to the 80 billion in certified evasion, there are at least another 23 billion on which the relationship between the administration and taxpayers can hardly be called 'tax-friendly'. According to the annual report on the development of tax disputes in 2023 filed by the Department of Tax Justice on Friday 14 June on the Mef website, the total value of disputes filed last year at the two levels of justice is approximately EUR 23 billion. The average value of cases was €131,453 with a caseload of 175,288 cases filed. A value that, as the report explains, remains substantially in line with the previous year despite the reduction in the number of disputes received in 2023 of -6.28% (-11,754 disputes).
Where disputes weigh the most
.The average value of a single first instance appeal, which on a national level is €103,767, is significantly higher in the province of Bolzano (€406,810), in Lombardy (€304,728), in the province of Trento (€251,564), in Lazio (€232,688), in Piedmont (€189,083) and in Veneto (€186,532). While in the South there is more litigation but for lower amounts. The lowest average values are in fact recorded in Calabria (25,835 euros), Sicily (28,571 euros), Sardinia (63,908 euros) and Basilicata (65,605 euros). The weight of cases inevitably grows on appeal, with a national average value of 235,230 euros. And always in the North, the highest values of disputes are recorded, such as in the province of Trento (€980,239), in Lombardy (€760,672), except in Abruzzo (€651,540), in the province of Bolzano (€578,275) and in Veneto (€568,772). The lowest average values are recorded in Molise (44,002 euro), Calabria (56,297 euro), Sardinia (62,089 euro) and Sicily (62,193 euro).
Bagatelle queens of causes
.More than 1 in 2 cases is still for minimal amounts. In 2023, in the first instance 57.8% of new appeals have a value less than or equal to EUR 5,000 (a total of EUR 95 million or 0.7% of the total value). 16.7% have a value between €5,000 and €20,000 (for a total of €246 million or 1.7% of the total value), while only 1.3% of total appeals concern disputes with a value of more than €1 million. But these, despite their low incidence in percentage terms, account for 69.8% of the total value of new litigation, i.e. over €10 billion.
The IRS prevails over the taxpayer
.The national victory index of the Inland Revenue is 79.2%, which is equivalent to saying that, as the report explains, 'about 4 out of 5 judgments passed in 2023 totally or partially confirmed the office's claim'. The regional directorates with the highest index of victory over the citizen even above the average are 15. In first place are the offices of Basilicata, where the margins of victory for citizens stop at less than 9% and with the tax authorities able to win 91.6% of cases, It does not go so much better to the Piedmontese with offices that win in 89% of disputes or in , Friuli Venezia Giulia with a victory rate of 87.1% or in Trento (87.0%) and Emilia Romagna (86.1%). The regional directorates with the lowest win rates are: Bolzano (55.3%), Valle d'Aosta (69.2%) and Pescara (74.5%).
Administration wins on VAT and unified contribution
Among the taxes for which the tax authorities and taxpayers come into conflict is VAT, perhaps also because of the primacy that this tax holds as the most evaded tax. Indeed, the Department's report shows that the tax where the office has the highest success rate is VAT with 57%, although in 58.2% the offices win on the unified contribution. Returning to taxes and lin taxes in third place is Irap (54%), followed closely by Irpef and Ires. Taxpayers win the most on local taxes (43.8%), car taxes in 33.6%) and waste tax (33.4%).

