Motivazione e (onere della) prova nel processo tributario riformato

The introduction of an “autochthonous” rule in tax litigation is the opportunity to test the stability of power’s relationships between tax authorities and taxpayer in the distri- bution of the burden of proof, and to question the reciprocal interactions between moti- vation and proof, as well as the nature itself of the tax litigation and the perspectives of the revision of the Taxpayer’s Bill of Rights.