The decreasing trend of pending tax disputes also continued in 2019, which decreased by 10,5% compared to 2018 (335.262 disputes pending at 31 December 2019). The result was reduced by the overall disputes received by the Tax Commissions of 10,2% compared to the previous year. In particular, there was a decrease of 7,3% of the appeals presented in the first instance and 17,9% of the appeals presented in the second instance.

The settled disputes, equal to 228.247, also recorded an overall decrease of 9,8% compared to 2018; in particular the reduction is equal to 10,3% in the first degree and 8,5% in the second degree.

The total value of pending disputes amounts to approximately € 40,6 billion; 65,5% of them (equal to 219.489 units) have been in stock for less than 2 years, 28,4% (equal to 95.313 units) have been in stock for a period between 2 and 5 years and only 6,1, 20.460% (equal to 5 units) has been in stock for more than XNUMX years.

The overall value of the disputes filed in 2019 is equal to 22,8 billion euro and the average value of the individual tax dispute is equal to approximately 121 thousand euro. The comparison with 2018 records a percentage reduction in value of 5,5% (- € 1,3 billion). 82,6% of the total appeals received at CTP deals with disputes of a value less than or equal to 50.000 euros (for a total of approximately 827 million euros), while only 1,4% of the appeals concern disputes of a value greater than 1 million euros (for a total of 8,7 , 67,3 billion euros). XNUMX% of the appeals received at CTR deals with disputes with a value of less than or equal to 50.000 euros (for a total of approximately 350 million euros), while 2,6% of the total appeals concern disputes of a value greater than 1 million euros (for a total of 7,0, XNUMX billion euros).

The overall value of the disputes settled in 2019 is approximately € 24,7 billion, while the average value of the single dispute settled is approximately € 108 thousand.

In the first instance, 83,7% of the appeals defined concern disputes of a value less than or equal to 50 thousand euros (for a total of approximately 968 million euros), while only 1,3% concern appeals of value above 1 million euros (for a total of around 9,0 billion euros).

As regards the defined appeals, 70,2% of the total decisions concern appeals of a value less than or equal to 50 thousand euros (for a total of approximately 445 million euros), while 2,5% concern appeals of a higher value to 1 million euros (for a total of about 7,6 billion euros).

In both the first and second instance, the results completely favorable to the taxing institution are greater than the results completely favorable to the taxpayer and are respectively 46,8% in the first instance and 46,1% in the second instance; the outcomes completely favorable to the taxpayer are respectively 28,7% in the first degree and 34,1% in the second degree. The intermediate rating stands at 11,5% in the first instance and 8,3% in the second instance.

In 2019, the average duration of the tax process in the first instance is 608 days (equal to 1 year and 8 months), with an improvement of 81 days compared to 2018 and 150 days compared to 2017; in the second degree of judgment it stands at 906 days (equal to 2 years and 6 months), with a worsening of 50 days compared to 2018 and 134 days compared to 2017.

In 2019, a total of 1.464.833 deposits of deeds and digital documents were made out of a total of 1.887.746 deposits, equal to 77,6%.

In detail, 1.124.337 electronic filings were made in the CTP (59.625 appeals, equal to 41,9% of the total, and 1.064.712 counterclaims and other documents, equal to 80,2% of the total) and 340.496 electronic filings in the CTR (28.070 appeals, equal to 59,9% of the total and 312.426 counterclaims and other documents, equal to 84,2% of the total).