Incoming tax audit: how to prepare and how to defend yourself.
A questionnaire from the Agenzia delle Entrate, an invitation to the adversarial procedure, an on-site inspection at the company: these are manageable situations if handled methodically and without improvising. This guide explains what to expect and what to do, step by step.
The three channels of control
Automated and formal checks: cross-checks on the declared data, which arrive as communications or “avvisi bonari”, often definable with reduced penalties. Questionnaires and invitations: requests for documents and clarifications on specific transactions. On-site visits and audits: the inspection activity at the company, which ends with the “processo verbale di constatazione (PVC)”.
What to do immediately
Read carefully what is being requested and by when: deadlines are the first thing to keep under control. Involve your professional adviser immediately and respond in a complete but relevant way: deliver what is requested, organized and explained, not the entire archive.
YOUR RIGHTS The Statuto del contribuente (Taxpayers’ Bill of Rights) lays down precise rules: the auditors’ stay at the company is subject to time limits, you are entitled to assistance from your professional adviser and, before the act is issued the tax authority sends you a draft decision allowing at least 60 days for counter-arguments. Preventive adversarial proceedings (contraddittorio preventivo) are now the rule: use them—this is often where the position gets sorted out.
Documents in order, half the work
Consistent VAT (IVA) ledgers and VAT settlements, invoices and receipts aligned with telematic flows, contracts and supporting documentation for the main transactions, reconciled bank statements. The quality of the documentation sets the tone for the entire audit.
IF THERE IS SOMETHING TO FIX The sooner the regularization, the less it costs: ravvedimento operoso (voluntary disclosure/late correction) significantly reduces penalties as long as the violation has not been challenged. On the website you will find the calculator for an initial estimate.
THE MOST COMMON ERRORS Ignoring communications hoping they will go away; replying hastily without a strategy; providing more than requested; signing minutes without having your observations recorded in the minutes.
Information guide updated as of July 2026: it does not replace assistance in the specific case. If an act has already been served, deadlines are running: contact the Studio immediately.
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STUDIO PONCHIO — OPERATING GUIDE
Tax audit: how to prepare and defend yourself
The three channels of control, your rights in the adversarial procedure and the costly mistakes
Not all checks are the same
Receiving a communication from the tax authorities (Fisco) does not mean you are under audit. Understanding what type of check it is is the first step to respond in the right way, without alarmism but without underestimating it.
The three channels of control
1. Automated check
Agenzia delle Entrate cross-checks the data in the tax returns with payments and databases. This gives rise to compliance notices (avvisi bonari), which indicate unpaid taxes or calculation errors. They are often resolved by paying or correcting, with reduced penalties if action is taken within the deadlines.
2. Formal check
Here, the office asks you to produce the documents that justify the expenses (oneri), tax credits (detrazioni) and deductions (deduzioni) stated in the tax return. It is essential to keep and provide the evidence: if the documentation is in order, the check is closed with no consequences.
3. Audit and on-site access
This is the most intrusive check: the Guardia di Finanza or the Agenzia accede in azienda or in studio, examines records and documents and draws up an official report (processo verbale). It may arise from reports, anomalies in indicators, or form part of audit plans. From this, a notice of assessment (avviso di accertamento) may be issued.
What to do when an audit starts
Ask for and verify the authorization to access the premises and the stated reasons.
Notify your accountant (commercialista) immediately: you have the right to be assisted.
Have observations and requests recorded; each day of the audit must be documented in the report.
Make the requested documents available, without handing over more than necessary.
Maintain a cooperative but cautious attitude: what you state remains on the record.
The Statuto del contribuente sets limits on how long auditors may remain at the premises: no more than thirty working days, extendable by a further thirty in cases of particular complexity identified and reasoned by the head of the office. The limit falls to fifteen working days over a period of no more than three months, extension included, only for businesses on simplified accounting and for self-employed professionals. What counts is the days the auditors are actually present, not the calendar days between the start and the end of the audit.
Your rights in the adversarial procedure (contraddittorio)
From 2024, the prior adversarial procedure (contraddittorio preventivo) is generalized: before issuing most tax assessment acts, the Tax Authority must communicate a draft measure (schema di provvedimento) and grant you a deadline to submit observations. This is a concrete safeguard: if used well, it can prevent the assessment or reduce its scope.
Before issuing the act the tax authority sends you a draft decision and allows you a period of not less than sixty days to file counter-arguments or to access the file. The time limit under Article 12(7) of the Statuto del contribuente, which ran from delivery of the official report, was repealed by Legislative Decree 219/2023: the clock now starts from notification of the draft, not from the report.
The act must be reasoned: it must explain the facts and the grounds for the claim.
You can always request cancellation by self-remedy (autotutela) when the error is obvious.
Tools to settle
If a claim is well-founded, wholly or in part, the law provides ways to settle the position by reducing penalties.
Instrument
In summary
Voluntary disclosure (ravvedimento operoso)
Voluntary settlement, still available after the audit has begun and after the official report: it is barred only by notification of a liquidation or assessment act or of an irregularity notice
Settlement by agreement (accertamento con adesione)
Agreement with the office, reduced penalties and instalment payments
Acquiescence (acquiescenza)
Acceptance of the assessment notice with a reduction in penalties
Conciliation (conciliazione)
Agreement during the litigation phase
Self-remedy (autotutela)
Annulment of a flawed or incorrect measure
Mistakes that can cost you dearly
Ignoring a compliance notice (avviso bonario) and losing the penalty reduction.
Submitting documents or tax returns without the support of your professional advisor.
Letting the sixty-day period for counter-arguments on the draft decision lapse, or missing the deadlines to enter into a settlement by agreement (adesione).
Failing to keep evidence of costs, tax credits, deductions and allowances for the required period.
Facing the audit alone, underestimating the consequences of what is recorded in the minutes.
The role of the firm
We support you from the very first contact with the Tax Authority (Amministrazione) through to closure: review of the notice/assessment (atto), management of the adversarial procedure (contraddittorio), selection of the most convenient instrument and, if needed, representation in tax litigation. Preparing in advance, with bookkeeping in order and evidence preserved, is the best defense.
Studio Ponchio STP — Dottori Commercialisti — studioponchio.eu — information guide updated as of July 2026. It does not replace tailored advice.
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