Iaia and Jannon (Pavia and Ansaldo), risking long delays due to appeal on Maneuver

Possible long times, compared to the immediate effects on the balance sheets and liquidity of the banks, and the risk that the ordinary judge will not refer the matter to the Council due to "(misunderstanding) needs to protect the revenue". This is what Roberto Iaia (Of Counsel and Head of Tax Litigation of Pavia and Ansaldo) and Marco Jannon (Partner and Head of Tax of the same firm) write in a note regarding the constitutionality doubts raised by the ABI in the Parliament hearing on some measures of the Budget and the possibility of an appeal to the Consulta.

The lawyers therefore suggest that "the most effective place to correct the measures" in particular the lower Ires and Irap deductibility and the installment plan over ten years of the superbonus credits remains the parliamentary examination".

As for the remedies, in fact, they state "the ordinary and prudential way, to avoid tax disputes, with increased penalties and interest, goes from a trial on an express or tacit denial to a request for reimbursement, on which to base a request for referral to the tax judge of the constitutionality questions of the Consulta". "However - they add - the times would be long compared to the immediate effects on balance sheets and liquidity. Furthermore, (misunderstood) needs to protect revenue could dissuade judges from referring it to the Consulta or from ruling on (un)constitutionality".