The European Commission has formally asked Italy to amend the VAT chapter of the tax amnesty scheme it has adopted. The contested measure grants taxpayers immunity for previous tax periods in return for a one-off payment exempting them from all administrative controls. No further legal action may be taken against the person concerned even if subsequent proof of irregularities comes to light. The Commission considers that such a blanket and indiscriminate renunciation of controls on VAT and the collection of any additional sums undermines the functioning of the harmonised system and the proper collection of Community own resources. The request is in the form of a reasoned opinion, the second stage of the infringement procedure provided for in Article 226 of the EC Treaty. If it does not receive a satisfactory reply within two months of receipt of its reasoned opinion, the Commission may bring the matter before the European Court of Justice.

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