Ruolo straordinario e misure cautelari preclusi se l’accertamento è annullato

The article analyses the repercussions of the Supreme Court ruling in which the Grand Chamber (“Sezioni Unite”) stated that the extraordinary measures in tax collection (“ruolo straordinario”) cannot be imposed upon the taxpayer when the notice of assessment has been declared illegitimate by any tax court ruling, including non-final statements. The novelty of the ruling must be appreciated as it seems to be applicable also to all precautionary measures different from the extraordinary tax collection, including in particular administrative holds. Also them should lose their effectiveness when any ruling, including intermediate ones, upholds the appeal of the taxpayer in the judgment concerning the underlying notice of assessment.