La tassazione indiretta del trust: quali prospettive ermeneutiche? – Parte Prima

The indirect taxation of the trust is characterized by a meager, approximate and unhappy regulatory framework, a source of many conflicts and uncertainties on the hermeneutical level: faced with the tendential immobility of the financial administration, over the years there has been a diachronic dynamism of jurisprudence. The first part of the essay analyzes the problems underlying the indirect taxation of the trust, in the light of the diachrony of the sources and positions initially assumed by the administrative practice and by the jurisprudence of merit and legitimacy.