The tax authorities have started surprise checks on 500 large taxpayers, bypassing risk analysis and notification deadlines, which raises legal issues.

After the expiration of the deadline of October 29, 2025, in the last week of November, approximately 500 large taxpayers were subjected to unexpected tax audits, informally selected by the tax authorities. These audits, which should have been preceded by a risk analysis, bypass the notification procedures and the 30-day period for clarifications, established by the PNRR.

The practice of unexpected audits raises serious legal issues, as they have a strict and limited objective, and their systematic use turns the audit into a 'probe hunt', contrary to the principles of law and European jurisprudence. This approach by the tax authorities creates a dangerous precedent, affecting the essential guarantees of taxpayers. In the upcoming period, solutions will be presented to defend their procedural rights.