New tax disputes -10%: towards 2016 levels One in two appeals for local taxes

If it is true that litigation remains historically high, one has to wonder what fuels taxpayers' appeals. The quantity and quality of tax assessments, the effectiveness of the fight against tax evasion, the desire to use the process as a delaying tactic to delay the payment of taxes: these are possible explanations, but they are not measured by statistics. Looking ahead, the tax reform does not strengthen the deflationary institutions.

Rather, the promise seems to be to change the tax-taxpayer relationship for the better, so as to anticipate and avoid possible litigation. One thinks of the increasing use of compliance letters, collaborative compliance extended to a growing number of businesses, and the two-year arrangement with tax authorities. Indeed, according to a statement by the Deputy Minister of the Economy, Maurizio Leo, in March, the effect of the new ex ante relationship with the tax authorities was already seen in the reduction of appeals in the first months of 2025.

In addition, the extension to 29 August 2026 of the deadline to implement the tax delegation may also allow the Government to intervene on the justice machine, to standardise the system, legal status and role of tax magistrates to that of 'ordinary' colleagues.

In 2025, 49.3% of new appeals concern local taxes. Among the disputed taxes, Imu and Tari stand out, probably also in the light of the anti-collection campaigns started by some local administrators.An indirect confirmation comes from the Court of Auditors (resolution 14/2025), according to which 'the tax revenues of municipalities remained stable between 2022 and 2023, but in 2024 they increased, thanks mainly to a higher collection of Imu and Tari'. It is reasonable to expect that a tightening of tax collection may have led to an increase in litigation in addition to higher collections.

Among other taxes by number of appeals, Irpef (14.6%), VAT (7.8%) and IRES (3.8%) follow. The number of disputes on Irap has dropped by half in absolute terms compared to 2019.The distribution of appeals on the territory in some cases photographs the specificities of the economy. In Lombardy there is 17.3% of cases on Ires, driven by the higher number of corporations based in the region. The port activity of Genoa and Naples probably explains why these two regions are in third and second place for the spread of litigation on customs duties.

Which is the tax that makes IRS and taxpayers quarrel the most? If we look at the total number of new appeals, Irpef is on track to close 2025 with almost 24,000 litigations, surpassed only by Imu, which saw 29,600 last year and is not likely to deviate much this year, although the detailed figure is not yet available.

In order to have a measure of litigiousness in the strict sense, however, it is necessary to relate litigation to revenue from individual taxes. There is an unavoidable time lag, because the appeals filed in a certain year always concern notices referring to previous tax periods, and therefore can only be related to the revenue of that year with a certain approximation. But the long-term trend and the difference in magnitude between the different taxes are still indicative.

We thus see that registration tax and mortgage and cadastral taxes excel in this 'litigiousness index', which measures how many new appeals are lodged per year for every 10 million euros of revenue for the public coffers (according to data from the Tax Revenue Bulletin). Specifically, in 2025, registration tax has an index of 9.8 appeals and hypocatastals of 13.1. In both cases, the figure is significantly lower than in 2019 - the last year before Covid - but remains at the highest level of the different taxes compared.

Irpef stops at just one appeal for every 10 million in revenue, with substantial stability from 2019. The number of disputes - although high in absolute terms - is diluted in the more than 235 billion of annual personal tax revenue (2024 figure). Not least because 99 billion come from withholdings from private sector employees and another 94 billion from public employees. With a mechanism - that of deductions - that confirms itself as the mainstay of public revenue and has the advantage of generating little discussion between the IRS and taxpayers.

The litigiousness of VAT, the other queen of public revenue with almost 181 billion in revenue, is also moderate. Here new appeals stop at 0.7 for every 10 million euro of revenue. This is a fairly constant figure over time, and even surprising given that Italy does not shine for tax gap at EU level. But evidently the revenue is so substantial that the impact of tax assessments and the new disputes that arise from them has been reduced.

On the other hand, the litigiousness of IRES is decreasing (from 2.3 appeals for every 10 million in 2019 to one in 2015) and also that of IRAP (even from 2.7 to 0.8). If in the case of IRES it is difficult to venture an explanation, for IRAP one could see the first effects of the simplification resulting from the exemption of taxpayers operating as individuals: a change of approach that has, among other things, overcome many discussions with the financial administration, such as those on self-organisation.

The counterbalance is the increase in litigiousness in the heterogeneous category of other state taxes, which will rise above the threshold of 26,000 litigations in 2025 (litigiousness, however, low in relation to other taxes: 2.2 appeals).

That leaves Imu, which constitutes a significant slice of local tax litigation. This property tax (together with Tasi and the old Ici for previous years) generates a very high number of appeals - i.e. 7.4 for every 10 million in revenue in 2024 - considering the relative simplicity of the tax, which is almost always based on cadastral rents. The impression is that many of these disputes are fuelled by specific anti-evasion campaigns conducted by municipalities and the attempt of some taxpayers to use the process to postpone payment.