Il principio del contraddittorio nella giurisprudenza tributaria della Corte di Giustizia. Il caso Sopropé.

In this important case the Court has declared that the taxpayer’s right to a proper hearing, as part of the rights of the defense, is a general principle of EC law which applies where the tax authorities are minded to adopt a measure which will adversely affect an individual. In our system, lacking a general written clause, its effective application raises important questions. It could be questioned whether the mentioned principle applies to all tax proceedings, regardless a regulatory and compulsory rule of law.