Tax authorities: single judge pushes for the settlement of minor disputes
Litigation. The number of cases settled at first instance involving claims of up to 5,000 euros has risen by 30.5 per cent over two years. Only 10.2 per cent of decisions handed down by a single judge are appealed, compared with 22.1 per cent of those handed down by a panel of judges
Over the course of two years, between 2023 and 2025, tax disputes involving amounts of up to 5,000 euros settled at first instance by a single judge rose by 30.5 per cent (from 79,785 to 104,120). This is not merely a sign that the judicial system, in the lowest value bracket of disputes, has learnt to step up its pace. The decisions of the single judge also reveal another effect: only 10.2 per cent of their rulings are appealed, less than half the 22.1 per cent of those handed down by panels of judges. The single judge, therefore, does not merely provide a driving force towards the closure of cases. In the vast majority of cases, they close them whilst ensuring their soundness. This is borne out by the figures contained in the analysis by the Tax Justice Department headed by Fiorenzo Sirianni (who has just been reappointed by the Government to the post for a further three years) on the new procedures in tax litigation introduced by the litigation reform measures.
These figures explain the government’s decision, under the PNRR decree issued at the start of the year (Decree-Law 19/2026), to expand its remit, doubling the threshold for appeals served since 2 May from 5,000 to 10,000 euros.
The process, however, begins in 2023. Within six months, the threshold was raised: initially set at 3,000 euros for appeals served from 1 January (a measure contained in Law 130/2022 on the reform of the justice system and tax proceedings), it was subsequently raised to €5,000 by Decree-Law 13 for appeals served from 1 July of the same year. Now, Decree-Law 19/2026 completes the latest increase to €10,000. In practice, the jurisdiction of the single judge has more than tripled in three years.
This development has reinforced the momentum in this direction, under the leadership of Deputy Minister for the Economy Maurizio Leo. In terms of timeframes, the benefit is tangible, albeit not dramatic. In 2025, a case involving up to €5,000 decided by a single judge took an average of 290 days, compared with 297 days for a panel decision on cases above that threshold. The gap is more pronounced in terms of the time taken to file the ruling: 30 days for a single-judge hearing compared with 41 days for a panel hearing.
The real difference, however, lies in the rate at which judgements are upheld. ‘An analysis of the 2025 data shows that at first instance,’ explains the Department of Tax Justice, ‘the percentage of appeals against single-judge rulings involving amounts of up to 5,000 euros – 10.2 per cent – is lower than that recorded for rulings issued by a panel of judges, which stands at 22.1 per cent.”
