Per il contraddittorio endoprocedimentale tributario occorre un nuovo art. 12-bis nello Statuto del contribuente, non l'art. 5-ter del d.lgs. n. 218/1997

The article is inspired by the recent Revenue Agency newsletter number 17/E/ 2020 to carry out some systematic considerations on the intra-procedural right defense in taxation matters and on the relationships between the tax authority, legislator, and taxpayers. The inadequacy of the new tool pursuant to art. 5-ter of Legislative Decree no. 218/1997 is highlighted. It also underlines the need to dedicate a specific rule of law providing more complete procedural guidelines for tax controls from remote, also in light of the highly likely greater practical relevance that they will assume after the 2020 health epidemic