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Analysis of ruling no. 32274 of the Court of Cassation regarding preventive seizure and tax fraud, with particular attention to the implications of transferring sums abroad.
Analysis of the recent ruling by the Court of Cassation regarding fraudulent declaration and the use of invoices for non-existent transactions, with a focus on the legal implications for the companies involved.
abuse of rights accountant accounting documents acquittal active repentance administrative liability administrative sanctions administrators adversarial proceedings ancillary penalties appeal appeal documents assessment assistance expenses atypical evidence bankruptcy buildability burden of proof business income cadastral classification capital companies capital gains case law co-debtors collection collection agent compensation compliance visa concealment confiscable profit confiscation consolidation contradictory corporate group Court of Appeal of Ancona Court of Cassation criminal law criminal liability criminal report cross-border damages compensation de facto administrator deductibility deductible expenses difference from withdrawal disability dispute violation disputed expenses dissolution of company documentary evidence earthquake enforcement act environmental hygiene fee equal treatment evidence execution executive title exemption expense compensation extension of terms false declaration false invoices fictitious revenues financial administration Financial Police fiscal justice fraudulent bankruptcy fraudulent declaration fraudulent subtraction home access illicit proceeds IMU income tax inducement to error integration invalidity invoices Italian jurisprudence judgment judgment no. 10270 judgment no. 30092 judicial police land land subdivision legal costs legal entities legal expenses legal liability limited liability company liquidation liquidators litigation consortium local taxes minutes of contestation money transfer motivation municipal regulation ne bis in idem non-deductibility non-existent transactions non-punishability of the taxpayer non-taxability nonexistent invoices notice of injunction notification notification deadline office registration omitted payment omitted VAT payment opposition order order 10294 order 10795/2024 Order 10939/2024 order 307 order no. 10615 Order No. 10788 ordinance payment notice payment notices personal income tax precautionary measures prejudice Presidential Decree 602/1973 presumptions preventive seizure professional liability property taxation proportionality refund registration tax regulatory uncertainty relevance res judicata effect Revenue Agency role extract ruling ruling 16576/2023 ruling 1810 ruling 37248 ruling 834/2025 ruling 9446/2024 ruling 9646 ruling 9733 2024 ruling 9900 ruling 9947 ruling no. 10310 ruling no. 11660 ruling no. 30092 ruling no. 41721/2024 ruling no. 46753 ruling no. 936 ruling no. 9556 rulings sanctions screen company sector studies seizure sentence 10298 Sicily smuggling statute of limitations subjective inexistence supplementary declaration Supreme Court Supreme Court 2024 Supreme Court ruling suspension of collection suspension of enforcement activities synthetic assessment tax tax acts tax administration tax assessment tax assessments tax audits tax collection tax consultants tax credit tax crimes tax evasion tax exemptions tax fraud tax law tax liability tax litigation tax notice tax offense tax penalties tax proceedings tax regulations tax trial taxation taxes threshold of punishability transfer of excess TUIR unavailability undue compensation unjustified compensation usufruct VAT VAT credit VAT refund VAT regulations verbal transfer withholdings