The course aims to explain the regulations concerning the tax trial, starting from the examination of the investigation powers of the Amministrazione finanziaria [Tax Authorities] and from the assessment activity of the Agenzia delle Entrate [Inland Revenue Office], taking also into account the notification of tax deeds and the measures to avoid tax litigation. Special attention will be devoted to tax collection, taking also into consideration the forms of taxpayer’s protection against coercive collection. With a view to ensuring suitable training when conducting litigation in the future, topics will be dealt with by continuously making reference to practical cases (also with drafting examples of the main deeds of the tax trial) and to the evolution of case law.

KNOWLEDGE AND UNDERSTANDING: Training activities aim to develop in students skills to analyse regulatory texts, as well as logical connections between procedural and procedural institutions and tax discipline. The student will masterthe discipline of the assessment and the tax process,as well as initiate a professional consideration of the issues, with the acquisition of a method of approach to problems theoretically firm but aware of the practical implications. The necessary knowledge can thus be acquired for the student who is interested in working professionally in the business consultant sectors, as well as in the practice of the profession of the taxman, judge of tax commissions, an official of the tax agencies and the tax offices of public and private administrations. Skills are acquired with the frequency of frontal lessons and with the constant use of references to concrete acts and cases, These skills are verified by passing exams, classroom discussions and case analyses, including using slides, materials and other multimedia content available on the platform. ABILITY TO APPLY KNOWLEDGE AND UNDERSTANDING: The student will learn an in-depth preparation on the issues of the investigation and the tax process with particular regard to the administrative profiles of the investigation process and the procedural aspects of the litigation. Knowledge is acquired with frequent contact at frontal lectures and with the constant use of references to concrete acts and cases and, in particular, to jurisprudence; all necessary materials will be provided to students. This knowledge is verified by passing examinations, classroom discussions, analysing cases and materials, as well as simulating a tax process. AUTONOMY OF JUDGMENT: The student will have acquired an ability to assess and judge on tax issues with particular regard to the investigation process and the rights of taxpayers, as well as to the defence of taxpayers in the process. It will then acquire skills to analyse problems and situations, the ability to identify the relevant regulations, the procedures appropriate to the situations and the consequent identification of solutions for practical cases. These capabilities are verified not only through passing exams, but also classroom discussions, case analysis and simulations.. COMMUNICATION SKILLS: The student will have to masterre the legal lexicon and acquire a terminological precision in the matter of tax law and an appropriate argumentative ability. In particular, it will have to acquire the ability to manage the comparison with the Financial Administration both in the prodromic phase at the investigation and in the procedural phase. These skills are verified through exam tests, as well as case processing and discussion and participation in problem-solving lessons.. LEARNING CAPACITY: The student at the end of the course will acquire in particular the ability to identify and interpret any changes in legislation and new doctrinal and juridential guidelines, having acquired a degree of knowledge to develop learning skills that will allow him to continue to update himself, even on his own. These capabilities are acquired through the preparation of exam case and analysis.

The first part of the course will focus on topics concerning the Tax Authorities’ control activity and particularly, powers of investigation and authorizations, accesses, inspections and controls, banking enquiries, the conclusion of the investigation activity (the formal notice of assessment). Then the main focus will specifically be on the tax assessment (assessment notice: nature, requirements and contents; types of assessment; documentary evidence and assumptions), as well as on the activity of coercive collection of taxes. The second part of the course will deal with tax special jurisdiction and its corresponding competence, examining also acts against which an action may be brought. Special attention will be devoted to appeal, by examining contents and mandatory requirements for validity, the lodgement of the appeal and the appearance before the court of the appellant and of the respondent and all the proceedings course to the issuance of the ruling. The appeal and the appeal to the Cassazione [Italian Supreme Court] and the enforcement of the tax judgement will be then examined. The final part of the course will focus on the measures to avoid tax litigation (autotutela [internal review procedures], assessment by consent and conciliation).

Giuseppe Napoli - " "Defense of the taxpayer and power of the tax", Maggioli publisher, 2025. Moreover, the use of an updated code of fundamental tax laws is required.

- On-campus frontal teaching - case analysis - presentation of casestudies. Working groups will also be organized among students with presentation in the classroom and evaluation of the results achieved and the exhibition capacity.

Attending students are required to: a) Participate in one of the Working Groups; b) Create a brief memoir of a word page on a topic of your choice among those that will be indicated at the beginning of the course, to be reported during the oral exam. For these attending students, the total activity carried out in points a) and b) above constitutes 70% of the final grade and the remaining 30% of the final grade is made up of the oral exam (i.e. questions on the entire program of the course). For non-attending students (or who have not profitably participated in the Working Groups and completed the brief memory), the final mark is entirely attributed (100%) during the oral exam (questions on the entire program of the course)

The minimum mark to pass the exam is 26/30.