New regulation requires justification for Tax Inspections in Italy

The Italian Revenue Agency and the Guardia di Finanza will no longer be allowed to inspect businesses or professional offices without a clear written justification. This major change comes from a proposed amendment to the tax decree by Vito De Palma of Forza Italia.

The amendment follows a ruling by the European Court of Human Rights (ECHR) on February 6, 2025, which condemned Italy for violating privacy rights during tax inspections. The Court found that inspections often lacked proper safeguards and could lead to abuse of power.

Inspections must now include a written explanation for why they are being carried out. This justification must appear in both the authorization request and the final inspection report. Without proper justification, inspections may be considered invalid and open to legal challenge.

The amendment is currently being discussed in the Finance Committee. If approved, it will apply only to future inspections. Past inspections will not be affected.