The Italian Supreme Court (Corte di Cassazione) has drawn a clear line, distinguishing between imposing sanctions and simply recovering due payments. According to their landmark ruling, Sentence No. 10297, issued on March 18, 2026, this boundary cannot be overstepped. The new principle, set to significantly impact thousands of tax cases, stipulates that if a taxpayer’s debt to the Italian Treasury is being regularly extinguished through an active payment plan or installment agreement, the Agenzia delle Entrate (Italian Revenue Agency) is prohibited from confiscating their assets, even if the individual has been convicted.
