The Income Revenue Agency with the circular n. 6/E/2020 published on March 23, 2012 promptly intervened in order to clarify the significance of the above mentioned D.L. in relation to the institution of the “accertamento con adesione” provided by Legislative Decree 218/97.
The doubt that arose – which immediately aroused the interest of tax law operators – concerns whether article 67 (suspension of the Agency activities from 8.03.2020 to 31.05.2020) is applicable to the aforementioned institution by virtue of its typically “administrative connotation” or the article 83 is applicable instead (suspension of the procedural terms of Tax Justice from 9.03.2020 to 15.04.2020) if the goal is to enhance the effect that the same institution produces from a procedural pint of view, i.e. to suspend the terms of the introductory appeal.
Well, according to the technicians of the Agency it would find application the art. 83 of the Decree.
Being, therefore, preferred the approach mentioned, analogous reasoning must be carried out relatively to the hypothesis in which the overlapping of the period of suspension under the DL 18/2020 with the ordinary period pursuant to article 6, comma 3, D. Lgs. 218/97, so, from the notification of the tax act the deadline to appeal will be 150 days (60 ordinary term + 90 adhesion) in addition to that (38 days) of extraordinary suspension for the effect of the “Cura Italia” Decree. (CL)
