The Italian Revenue Agency (IRA) has published Provision (Prot.) no. 356446/2022 of 16 September 2022 for the implementation of Article 5 of Law No. 130 of 31 August 2022 on provisions for tax justice. Under Article 5, pending tax disputes may be settled through the payment of a percentage of the disputed amount, net of interest, default penalties, etc. as follows: 5% if the net amount does not exceed EUR 100,000 and the IRA has been unsuccessful in all previous stages of the dispute (i.e., the taxpayer won in all lower courts); and 20% if the net amount does not...