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Reconstructing revenue: the limits of the analytical-inductive assessment

Mark-up percentages, stock movements and bank data: when the tax office may adjust declared revenue, and how to prepare the defence.

Even where the books are formally in order, income may be adjusted if the declared figures appear unreliable taken as a whole.

The analytical-inductive method

Art. 39(1)(d) of DPR 600/1973 allows the tax office to reconstruct individual components of income on the basis of presumptions, provided they are serious, precise and consistent. The usual tools are mark-up percentages applied to the cost of goods sold, movements in stock levels and the findings of financial investigations.

How to build the defence

The defence turns on the coherence of the figures: documenting the pricing policy actually applied, the make-up of closing stock and the reasons for any departure from sector averages, and putting all of this forward already at the contraddittorio preventivo stage. The firm helps businesses check these indicators in advance and manages the assessment.

• Adjustment assessments – art. 39(1)(d), DPR 600/1973.
• Presunzioni semplici – art. 2729 del codice civile.