Sanzioni amministrative tributarie e incertezza normativa oggettiva

[Autom. eng. transl.] According to the Supreme Court, in line with the provisions of art. 6, legislative decree no. 472 of 1997, which contemplates separately the objective conditions of uncertainty on the scope and scope of application of the provisions to which they refer and the inevitable ignorance, the objective regulatory uncertainty constitutes a different situation compared to the innocent subjective ignorance of the law. The assessment of the first is entrusted exclusively to the judge and cannot be operated by the administration. Furthermore, objective regulatory uncertainty does not have its foundation in justified ignorance, but in the impossibility, once the state of ignorance has been abandoned, in any case to arrive at the state of certain knowledge of the tax law.