L'accollo del debito d'imposta e il "nuovo" divieto di compensazione

Research output: Contribution to journalArticlepeer-review

Abstract

Article 1 of Decree Law no. 124/2019 introduces a derogation from tax compensation provided for in art. 8 of the Statute of taxpayers’rights, by changing the discipline of taking over the debt. The previous discipline is accompained by a new rule, to be applied only if the person who takes over the debt of others violates the proibition to offset it withown claims. In some cases, the new rule adds to the guarantees offered by the principal debtor the guarantees offered by the guarantor, obligated jointly and severally to pay the debt. In other cases, the new joint and several liability shall result in the shifting of the tax credit protection from the area of contractual guarantees to the area of legal guarantees.
Original languageItalian
Pages (from-to)961-984
Number of pages24
JournalRASSEGNA TRIBUTARIA
Volume4
Publication statusPublished - 2020

Cite this