Tax litigation, 3.2% decrease between October and December 2025
Over 50,000 new disputes have landed in the courts. The value of litigation in first and second instance exceeds 24 billion
Tax litigation drop in the period October-December 2025. A decrease of 3.2% compared to the same quarter in 2024. New disputes before tax courts totalled 51,304 (38,592 at first instance and 12,712 on appeal). Litigation in first and second instance before tax courts is worth a total of €24.2 billion.
The figure comes from the Department of Tax Justice in the statistical report of the Quarterly Tax Litigation Report published on 20 March 2026.
The report numbers
Looking at the whole year 2025, the department shows that, at a national level, a total of 202,280 disputes were settled, of which 155,500 first instance appeals (-14.6% compared to 2024), worth 16.0 billion, and 46,780 appeals (+9.8% compared to 2024), worth 8.2 billion. In the same period, a total of 223,847 disputes were settled, of which 173,258 were settled at first instance (+5.3% compared to 2024), with a value of €14.9 billion, and 50,589 at appeal (-5.2% compared to 2024), with a value of €9.3 billion.
57.3% of new appeals in the first instance have disputes with an economic value of up to EUR 5,000, representing less than 1% of the total economic value, while 1% of the disputes have a value of more than EUR 1 million and represent more than 66% of the total value. In the second instance, more than 43% of new appeals have an economic value of up to EUR 5,000, representing 0.4% of the total economic value, while 2.1% of disputes exceed EUR 1 million, representing approximately 76% of the total value of appeals.
Extending the analysis to the value range of 0 to 10,000 euros, we find that it concerns 66.6% of first instance disputes (with 1.7% by value) and 53.2% of appeals (with 0.8% by value).
