The article analyzes the reform of the “general review” of the questions carried out by the Government thanks to the delegation conferred by Art. No. 6, paragraph 6, of Law No. 23/2014.

In this reform, the introduction of a question covering all cases of “abuse of law”, unlike the “special” one governed by Art. No. 21 of Law No. 413/1991, is certainly one of the most significant and appreciable innovations.

This novelty represents an evolution, as it is in line with the regulations on the “abuse of law”, and guarantees its relative “dignity” as a general and fundamental institution of our tax system. Not only that, it overcomes the critical aspects of the previous discipline of the “special” question, i.e., the impossibility of making use of it for any potential circumvention, the excessive length of the deadline of response and the need for the requested body to issue a formal notice for the operation of the “tacit consent”.

Annex