In 2025 compared to 2024, there was an 80% increase in the number of taxpayer appeals to the Tax Dispute Resolution Directorate (DDS) of the AADE, i.e. the service for reviewing tax administration acts without recourse to the administrative courts.

The procedure at the BAD is free of charge, electronic and a simple petition is sufficient to examine in depth the case of any taxpayer seeking correction or cancellation of the tax and penalties imposed on him/her. It is a mandatory administrative step before going through the judicial route and a decision is issued within 120 days or, if the deadline passes without a decision being issued, the appeal is deemed to have been implicitly rejected.

However, in the past year, according to the data of the 2025 Report of the DPA, 99.2% of the cases decided were examined before the deadline set by law.

This performance was the best in the 13 years of operation of the institution of administrative review of tax cases and acts.

This was not the only record broken in the past year, however. In 2025 the BPA:

– received more than 11,000 appeals, the most that have been filed in just one year since 2016

-issued 85% more decisions than expected

-and 50% more than in 2024.

The same data also reveals a negative record: while on average in all previous years one in three taxpayers were granted a claim, in 2025 8 out of 10 claims were denied, or 83%.

Despite the clear variation in the rate of vindication recorded in 2025, it does not overturn the data, as in 2025 this change was mainly phenomenal: it is interpreted in relation to the specific weight of the cases on presumptive income, but also based on the legal framework shaped by the decisions of the CoE.

The big drop in approvals this year is mainly linked to the massive influx of appeals by freelancers and scientists on presumptive income, cases in which not only the application of the law in individual cases, but the regulatory framework itself was questioned. A similar phenomenon had been observed about a decade ago, when mass applications were submitted for the annulment of ENFIA, which, despite the expectations of the taxpayers, was eventually found to be constitutional.

In practice, as an administrative review mechanism, the BPA only verifies whether a tax measure has been issued and implemented in accordance with the law and the prescribed procedures. Although the filing of an appeal is a prerequisite for recourse to the courts, the Dispute Resolution Service is not competent to annul the legislative framework, which de facto limits the scope of its judgment in the specific category of cases that arose in 2025.

The figures from the AADE show that, if the mass appeals against the presumptive taxation of professionals are not taken into account, one in three taxpayers continued to win “battles” in the BCC in 2025.

The AADE’s figures show that, if the mass appeals against the presumptive taxation of professionals are not taken into account, one in three taxpayers continued to win “battles” in the BCC in 2025.

Specifically:

last year, 4,670 more cases were heard than were heard in 2024, demonstrating that the agency absorbed an unusually large wave of appeals in this category.

A total of 3,546 more applications were dismissed compared to 2024, a figure that represents 75% of the additional applications brought in for consideration, a development that explains why the vindication rate deteriorated drastically in 2025.

In addition to the limits of the BPA’s powers, the Council of State’s case law on presumptive income also contributed to this picture. With decisions issued by the Supreme Court (OI. STE 1800 – 1802/2025), the Plenary Session of the Council of State considered the relevant framework constitutionally tolerable and rejected the collective applications for annulment of the measure, shaping the broader legal environment in which the specific appeals submitted en masse were also examined, following the urging of legal and scientific associations.

In substance, however, the 2025 picture reflects both the contextual increase in the volume of cases brought for consideration in that year and the diversification of their subject matter, due to their special nature and composition.

On the contrary, as regards the cases for which the BPA is actually competent and which involve citizens and companies (following a tax audit or procedural errors in particular), the vindication rates in 2025 were still consistently at one third of the cases, as in previous years.

In this context, despite the visible decline in approvals, the BPA has not become a “decorative service” for receiving applications, but offers measurable economic benefits for 1 in 3 taxpayers (and especially small and medium-sized businesses who lack the means, the time or the stamina to fight multi-year battles in the administrative courts) while also contributing to the administration’s self-control, transparency and uniform application of tax legislation, with the decisions issued by it being notified to the tax authorities and publicly accessible to all on the website of the Independent Public Revenue Authority.

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