Ruling request not accepted are unappealable from 2016
The Supreme Court with decision n. 7497/2018 stated that the tax payer is allowed to appeal the ruling opinion of the Tax Authority but only till on 31th December 2015.
According to the new art. 6 of Legislative Decree 156/2016, now the negative opinion of the Tax Authority cannot be appealed. The tax Payer is allowed to appeal only the tax assessment of the Revenue Agency concerning the negative replayed in the Anti-abuse ruling procedure.
Andersen & Legal is at your disposal for any additional clarification and explanation.