Mark-up percentages, inventory and banking data: when the tax office may adjust declared revenue and how to prepare the defence.
Even where the books are formally in order, income may be adjusted if the declared figures appear unreliable when taken as a whole.
Article 39(1)(d) of Presidential Decree 600/1973 allows the tax office to reconstruct individual components of income on the basis of presumptions as well, provided they are serious, precise and consistent. The typical tools are the mark-up percentages applied to the cost of goods sold, movements in inventory levels and the findings of financial investigations.
The defence turns on the consistency of the figures: documenting the pricing policy actually applied, the composition of closing inventories and the reasons for any divergence from sector averages, and putting those elements forward as early as the contraddittorio preventivo (the pre-assessment exchange with the tax authorities). The network assists businesses in checking their indicators in advance and in handling the assessment.