Information and communication obligations in tax law: a transparency regime in relations between the tax authorities and the taxpayer

Over time, tax law has implemented a significant change in the regime of the subjective tax relationship, through the introduction of regulatory instruments that are emblematic of the progressive transition from a system that conformed the relationship between the taxman and the taxpayer to the binomial authority-subjection to a model based on the combination of collaboration and trust. The taxpayer is required to comply directly with the declaration and payment obligations, while the Financial Administration is charged with a subsequent activity, aimed at checking the correctness of the procedures followed by the taxpayer and, in the event of an irregularity, to exercise mandatory powers of authoritative intervention. In this perspective, the criteria established by the Statute of the rights of the taxpayers, approved by law 27 July 2000, n. 212, which sets out the general principles of the tax system and contains unique self-reinforcement clauses.