Practical guide
How to file a tax assessment settlement request with AI
4 min read · Updated May 2026 · Editorial oversight: Avv. Federico Papa
The tax settlement proposal is the primary out-of-court tool for resolving tax disputes. According to Art. 6 of Legislative Decree 218/1997, following the reform introduced by Legislative Decree 13/2024, a taxpayer can submit this request after the notification of a tax assessment, provided that the mandatory contradictory procedure on the 'draft notice' (schema di provvedimento) under Art. 6-bis of Law 212/2000 was not previously carried out. The main objective is to reach a settlement agreement which, if successful, leads to a reduction of administrative penalties to one-third of the statutory minimum. It is crucial to note that filing the request automatically triggers a 90-day suspension of the deadline for appealing the notice before the Tax Court.
In brief
The tax assessment settlement request under Art. 6 of Legislative Decree 218/1997, amended by Legislative Decree 13/2024, is the primary out-of-court tool for resolving tax disputes. Drafting, potentially involving AI, must occur within 60 days of the assessment notice, provided no mandatory dialogue on the draft measure under Art. 6-bis of Law 212/2000 was conducted. Submission via direct delivery, registered mail, or PEC automatically suspends the appeal deadline before the Tax Justice Court for 90 days. A successful agreement reduces administrative penalties to one-third of the statutory minimum.
The steps
- 1.
Verification of requirements and deadlines
The request must be submitted within the mandatory 60-day period from the notification of the tax assessment. It is essential to verify that the notice was not preceded by the mandatory contradictory procedure on the draft notice under Art. 6-bis of Law 212/2000, as in such cases, the request under Art. 6 would be inadmissible. The practitioner must precisely calculate the days elapsed since notification to avoid forfeiting the right to access this simplified procedure.
- 2.
Identification of the office and the challenged notice
The document must be addressed to the Revenue Agency office that issued the assessment, clearly stating the assessment number and the date of notification. It is necessary to provide the taxpayer's identification data, including the tax code and the elected domicile for subsequent communications. Correct identification of the tax notice is the prerequisite for the Revenue Agency to open the investigation file.
- 3.
Drafting the request and legal references
The document must contain an express request to activate the settlement procedure, citing Art. 6 of Legislative Decree 218/1997. Although it is not mandatory to provide a detailed list of grievances at this stage, it is recommended practice to include a summary of the factual and legal elements justifying a review of the claim. This preliminary disclosure facilitates the preparation for the contradictory hearing by the assigned tax officer.
- 4.
Filing the request and transmission methods
The request can be submitted via direct delivery to the office, by registered mail with return receipt, or through Certified Email (PEC). For postal shipments, the mailing date is legally relevant; for PEC, the delivery receipt provides proof. It is essential to keep proof of filing to certify the suspension of procedural deadlines for filing an appeal.
- 5.
Managing the suspension and the settlement hearing
The 90-day suspension of the appeal deadline begins on the date of filing, pursuant to Art. 6, paragraph 3. Within 15 days of receipt, the office should issue an invitation to the contradictory hearing to examine the findings and schedule a meeting. During this phase, counsel must present supporting documentation capable of refuting or mitigating the original tax claim, acting in compliance with the principles of fair cooperation set out in Art. 10 of Law 212/2000.
Legal basis: art. 6 D.Lgs. 218/1997art. 5 D.Lgs. 218/1997art. 6-bis L. 212/2000art. 10 L. 212/2000D.Lgs. 13/2024
The template structure
The standard sections that make up the document. The full template can be opened and completed directly on edit.legal.
Destination Office
Specific identification of the Provincial Directorate of the Revenue Agency with territorial jurisdiction.
Applicant
Personal details, tax code, and contact information of the taxpayer requesting the settlement.
Tax Assessment Notice
Identification details of the received notice, including registration number, tax year, and date of service.
Settlement Request
Formal declaration of the intent to initiate the settlement procedure pursuant to Art. 6, D.Lgs. 218/1997.
Elements for the Contradictory Hearing
Summary of the factual and legal reasons supporting the request for tax claim review or renegotiation.
Place, Date, Signature
Handwritten or digital signature of the taxpayer or authorized counsel provided with a special power of attorney.
Mistakes to avoid
- Filing the request after the 60th day from notice, resulting in inadmissibility and loss of procedural benefits.
- Incorrect calculation of the 90-day suspension period for the appeal, which must be cumulated with the summer suspension of procedural terms (August 1-31).
- Refiling a second request for the same notice, which does not trigger any additional suspension of procedural deadlines.
- Failure to attach a special power of attorney if the request is signed exclusively by the legal counsel.
Frequently asked questions
Does filing the request always suspend tax payments?
Yes, filing the request suspends the deadline for appeal for 90 days and, consequently, the enforceability of the act for collection purposes under Art. 6, paragraph 3, preventing the initiation of enforcement procedures during this period.
What happens if the Revenue Agency does not summon the taxpayer?
Failure to summon the taxpayer does not invalidate the assessment notice. The taxpayer or legal counsel may still request a meeting at the office. In any case, upon expiration of the 90-day suspension without a signed agreement, an appeal must be served.
Is it possible to withdraw the request after filing it?
Yes, the taxpayer may decide not to proceed with the hearing and directly appeal the notice. Filing the request does not mandate reaching an agreement, but consumes the 90-day suspension period, which cannot be triggered again for the same notice.
What edit.legal automates
- —Automatic verification of legal references to Legislative Decree 218/1997 to prevent formal errors.
- —Assisted calculation of the 90-day suspension period to avoid forfeiture when filing a fallback appeal.
- —Guided structuring of factual and legal arguments for the contradictory hearing based on the type of assessment received.
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