Italy has introduced two major changes with the aim of encouraging tax compliance and, accordingly, cooperation between tax authorities and taxpayers, simplifying the relationship and reducing litigation as much as possible.

Existing deadlines for voluntary corrections to tax returns or mistakes made in past years have been extended in order to benefit from the related reduced penalties. Moreover, for taxes which are administered by the Revenue Agency, it will be possible to proceed with the correction even when an audit has already closed, up until a notice of assessment or a notice of liquidation is served. The consequence will be that even in the case of audit or challenge in a tax report, the taxpayer could still adhere to the amended tax liability resulting from the voluntary correction, contrary to the position under the previous rules. In such a case, the penalty is reduced to one-fifth of the minimum.

There is no specific deadline for making a correction if a Tax Audit Report has been issued. Thus, it should be reasonable to assume that the correction could be made until the notification of the notice of assessment.

The other change is that it will no longer be possible simply to accept the content of a tax report or tax assessment by paying all higher taxes assessed in their entirety, plus the related interest, and part of penalties (one-sixth) (the so-called acquiescenza rinforzata, which will be repealed as of 1 January 2016).