The article analyzes how the introduction of a “generalized” opposition approach would have made it possible to overcome the critical structure, based on the distinction between harmonized and non-harmonized taxes, consolidated following the judgment No. 24823/2015. It identifies the circumstances that, unfortunately, risk severely and even unreasonably limiting the scope of operations, such as: 1) the exclusion of partial assessments from the preventive opposition procedure; 2) the fact that some potential disputes on direct taxes and VAT and all those relating to non-harmonized taxes other than direct taxes remain outside the new rules’ scope. The author’s argument is that the objective that the reform should reasonably have achieved cannot be said to have been fully achieved.