Profili del nuovo concordato preventivo, rapporti con l'accertamento e con la riserva di legge

The structural aspects of the two-year preventive agreement are examined, in the light of the changes brought by the corrective decrees, and a composite rationale is discussed. It marks a new way of implementing the tax duty, by pre-determining its amount through statistical-mathematical methodologies.
Thus, it favours simplification and ex ante certainty of the tax as opposed to the precise measurement of incomes yet difficult to be assessed a posteriori. Tampering the tax duty creates strains, inter alia, with the rule of law.