THE NEW RESPONSIBILITIES OF TAX PROFESSIONALS: FROM NEUTRAL INTERMEDIARY TO CONDITIONAL GATEKEEPER WITH A GUARANTEE FUNCTION
Abstract Tax document marked for review on a laptop This article examines the evolving liability of tax professionals in Italian law after the Court of Cassation’s March 2026 rulings. It argues that these decisions do not impose a general duty to guarantee the legality of taxpayers’ conduct, but selectively extend liability through the rules on complicity in administrative tax offences. The analysis traces the erosion of the traditional neutrality of external professionals and shows how...