The New “Right of Questioning” and Its Effects for the Megaprojects Sector

The recent Italian tax reform reformed the s.c. “right of questioning” the Italian Revenue Agency, i.e. the right granted to taxpayers, both individuals and corporations, to ask for clarification to the Italian tax administration on spe-cific and personal cases concerning the cases set out under art. 11 of the Statute of Taxpayers’ Rights. If, on the one hand, the reform resizes the “right of question-ing” available to individuals, on the other hand, it reserves the availability of the so-called “probatory right of questioning” to the corporations that adhere to the cooperative compliance regime or that submit a “new investment right of question-ing”. This aspect denotes unequivocally an increasing tendency of the Italian legal system towards the early settlement of tax relations with taxpayers having a high ability to pay. This is clearly a circumstance that also affects those operating in the megaprojects as a sector that has, because of its nature, a very high economic and fiscal importance.