The qualification of “European citizens”, as well as “Italian citizens”, is not theoretical at all and includes, besides the subjection to duties, also the ownership of rights. Taxpayers are holders of rights and guarantees provided not only by national law but also by supranational laws.
Right and guarantees deriving from the European Union law have for some time now been instruments of daily use in the defense of taxpayers by the Firm, both as regard the rights and freedoms of economic content and as regard the violations of the tax directives or the legislation in the field of State aid.
In the last few years the so-called European system for the protection of Human Rights, based on the European Convention of Human Rights, the Nice Charter and the general principles of the European Union Law, has assumed increasing importance and concreteness also in tax matters.
In order to offer to its clients the best possible and the most fitting defense in the tax proceedings, the Firm uses all substantive and procedural legal instruments useful for submitting to domestic judges the arguments based on both traditional European tax law and on the mentioned European system of protection of Human Rights.
The aim is to widen, often in a decisive way, the defensive arguments so that they can also include – based on the EU Commission’s action on targeted topics - the rights that can be protected even in judgments ahead the extra-national bodies of justice: the European Court of Justice and the European Court of Human Rights, on which the Firm has gained a significant experience.