Revenue Agency tax audit guidelines for 2022: APAs, between lights and shadows

On 20 June 2022, the Italian Revenue Agency published the Circular Letter no. 21/E (the “Circular Letter”) containing “Guidelines on preventing tax evasion, as well as activities related to tax litigation, advice and services to taxpayers for 2022”. The indications therein provided are aligned with the contents of the “Act of Guidance for the achievement of fiscal policy purposes for the years 2022 – 2024” issued by the Italian Ministry of Economy and Finance.