Illegittimo l’aggio di Equitalia? Sì, secondo la Commissione Tributaria Provinciale di Treviso che si è espressa con la sentenza n. 325/1/2016, accogliendo parzialmente il ricorso proposto da una ditta che aveva impugnato l’intimazione di pagamento ricevuta da Equitalia e riferita a Iva, Ires, Irap, ritenute, addizionali per diversi anni. La Commissione – fa notare lo Studio Cataldi – pur respingendo i motivi di ricorso del contribuente, in quanto le imposte erano effettivamente dovute nella misura individuata dall’ufficio, ritiene che l’aggio non debba essere conteggiato. Quest’ultimo infatti, spiega la CTP, costituisce il compenso spettante al concessionario-esattore per l’attività svolta su incarico e mandato dell’ente impositore, per cui grava sul contribuente senza una giustificazione e senza un collegamento all’attività effettivamente svolta. In altre parole, rappresentando la remunerazione per l’attività svolta dal concessionario (Equitalia) nel riscuotere i tributi, l’aggio attiene al rapporto tra l’ente impositore e il concessionario del servizio stesso e non può dunque essere addossato al contribuente, inteso come soggetto estraneo a tale rapporto. In secondo luogo – aggiunge lo Studio Cataldi – la Commissione ha rilevato che l’aggio esattoriale, essendo un aiuto di Stato che la normativa assegna a un’impresa, si pone in contrasto con l’art. 107 del Trattato di funzionamento dell’Unione Europea, il quale stabilisce che sono incompatibili con il mercato comune gli aiuti concessi dagli Stati sotto qualsiasi forma che, favorendo alcune imprese, falsino o minaccino di falsare la concorrenza.
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