The Agrisud judgment and the future of tax inspection powers in Italy

In the Italian tax system, on-site access to and inspections of business premises by the Revenue Agency and the Guardia di Finanza are key tools of tax enforcement.

This framework has, however, been called into question by the European Court of Human Rights, most recently in its Agrisud 2014 S.r.l. judgment.

The ruling calls for a reconsideration of the current regulatory framework, highlighting the need for stricter authorisation requirements, effective judicial oversight, and a more balanced approach between combating tax evasion and safeguarding taxpayers’ fundamental rights.