ABSTRACT
Giulio Allevato and Carlo Garbarino analyze the evolution of a civil law system in Italy in dealing with tax avoidance. Echoing the topics developed in the first and the second part of the Companion, this chapter explores how the Italian legal doctrines related to taxation evolved from the initial adherence to the certainty principle of the rule of law, which is especially salient in the civil law systems, to embracing a general anti-avoidance rule (GAAR) inspired by various developments in taxation within the European Union. The chapter also addresses briefly the new Italian tax compliance initiative designed to facilitate the implementation of the GAAR.
