Findings at a glance
- Traceability of the calculation
- Completeness of the data basis
- Business-specific benchmark
- Requirements for counter-evidence
- Burden of proof and its reversal
- Official benchmark tables
- Data access and format
- Intensity of judicial review
5× exceeded · 3× met
Traceability of the calculationexceeded
The inductive assessment must rest on serious, precise and consistent indications.
CitationDPR 600/1973 art. 39 · DPR 633/1972 art. 55
What we provideEvery figure is traceable down to the individual document. The chain of calculation can be walked in both directions — from the result to the document and back.
Completeness of the data basisexceeded
Assessment is permitted even where the data is incomplete; a full survey is not required.
CitationDPR 600/1973 art. 39 c. 2
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
The taxpayer may rebut the indications with their own evidence in the adversarial procedure.
CitationL. 212/2000 art. 6-bis (Statuto del contribuente)
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 5 axes
Business-specific benchmarkexceeded
The ISA measure deviation from sector figures; proof specific to the individual business is possible but not provided for.
CitationD.L. 50/2017 art. 9-bis (ISA)
What we provideThe calculation rests on the recipes and quantities of the audited business, not on an industry average.
Burden of proof and its reversalmet
Where the accounts are defective, the burden of demonstration shifts to the taxpayer.
CitationDPR 600/1973 art. 39 c. 2
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.
Official benchmark tablesexceeded
ISA — synthetic indices of fiscal reliability, set anew each year on a scale from 1 to 10.
CitationD.L. 50/2017 art. 9-bis · jährliche Decreti MEF
What we provideThe actual mark-up of the business is determined and set against the official figure — with a reasoned classification.
Data access and formatmet
Electronic invoice data passes through the Sistema di Interscambio; accounting data must be produced.
CitationD.Lgs. 127/2015 · DPR 600/1973 art. 32
What we provideOutput in the audit formats required by the respective country; the raw data is preserved unchanged.
Intensity of judicial reviewmet
The tax court reviews the assessment in full.
CitationD.Lgs. 546/1992 · D.Lgs. 220/2023
What we provideThe dossier is built so that a court can follow it without having to calculate anything itself.