Il precedente del reclamo-mediazione nel sistema tributario francese

Abstract

The French legislator has paid attention to the out-of-court settlement of disputes. In the tax area has been introduced a pre-litigation procedure called réclamation préalable, which subordinates the establishment of the procedural relationship to a prior compulsory administrative stage, in some aspects, almost similar to that provided for art. 17-bis of Legislative Decree n.546/92 within Italian system of law.