Unlawful assessments of the Tax Authority
The Commissione Tributaria Regionale di Milano (the Tax Court of second instance) reiterated that the tax assessment notice by the Tax office about Life Portfolio International policies stipulated with Credit Suisse before fiscal year 2009 are unlawful (judgment no. 872 of 6th March 2017).
The Tax Court of second instance considered the retroactive application of art. 12 paragraph 2 of DL 78/2009 illegal and adopted the first-instance ruling mentioning that the tax laws have no retroactive effect as a result of art. 3 of Statuto dei diritti del contribuente and art. 11 of the law provisions.
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