Italy: Italy: Unchallenged Payment Demand Bars Later Tax Defenses
On 20 October 2026, the Italian Supreme Court (ordinanza no. 26283/2026) reinforced the principle that a taxpayer who fails to challenge a payment demand (intimazione di pagamento) within the prescribed deadline is precluded from subsequently contesting the validity of the underlying tax collection notice (cartella esattoriale) or invoking statute-of-limitations defenses that expired before the demand.
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