News · Tax · – 22 July 2026

«Radar» system tax assessments: data comparison and taxpayer protection

TOPIC
Tax litigation: the evidential value of automated cross-checks between databases.

Risk-analysis tools allow the tax authorities to compare a single taxpayer’s data with that of comparable subjects and with the information held in tax databases. This is, however, an aid to selecting audits and not evidence in itself: the results of an automated cross-check are, as a rule, merely circumstantial.

For the assessment to stand, the deviation detected must be turned into a reasoned challenge supported by concrete evidence, in compliance with the taxpayer’s right to be heard. The safeguards — statement of reasons, burden of proof and right of defence — therefore remain firm, and automation cannot erode them.

IN PRACTICE
When faced with an assessment based on comparative analysis, check the reasoning and request access to the benchmark data: an indication must always be confirmed by specific evidence.

Summary note by the CommercialistiAvvocati network, based on specialised legal and practice sources. The text does not reproduce original contributions and does not constitute professional advice.

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