L’art. 19 del DPR 602/73 prevede che le somme richieste mediante cartella di pagamento o accertamento “esecutivo” possano essere dilazionate fino ad un massimo di 72 rate mensili (dilazione “ordinaria”) o di 120 rate mensili (dilazione “straordinaria”).
Ciascuna rata, salvo situazioni eccezionali, non può essere inferiore a 50,00 euro e, per l’accesso alla dilazione, non è mai richiesta la prestazione di garanzia sotto forma di ipoteca o di fideiussione bancaria, a prescindere dall’entità del debito che si intende dilazionare.
Tale istituto opera per qualsiasi tipo di imposta e per i contributi previdenziali, quindi può riguardare, ad esempio, l’IRPEF, l’IRES, l’IVA, l’imposta di registro, l’IMU e i contributi INPS.
2 MODIFICHE ALLA DISCIPLINA DELLA DILAZIONE
La disciplina della dilazione di cui all’art. 19 del DPR 602/73 è stata riformata dall’art. 13bis del DL 24.6.2016 n. 113, conv. L. 7.8.2016 n. 160, e le novità, in sintesi, sono le seguenti:
- è stato innalzato da 50.000,00 euro a 60.000,00 euro il limite fino al quale la dilazione è concessa su istanza di parte, senza che sia necessario dimostrare lo stato di temporanea difficoltà economica;
- se il debitore decade dalla dilazione, può essere riammesso a condizione che, quando presenta la domanda, abbia pagato le rate scadute, a prescindere da quando è stato concesso l’originario piano di dilazione.
Non è prevista una specifica decorrenza per le novità indicate, quindi esse operano dal 21.8.2016, data di entrata in vigore della L. 160/2016, che ha convertito il DL 113/2016.
3 RIAMMISSIONE ALLA DILAZIONE PER I CONTRIBUENTI DECADUTI
L’art. 13bis co. 1 del DL 24.6.2016 n. 113, conv. L. 7.8.2016 n. 160, ha introdotto una riammissione alla dilazione per i contribuenti che, all’1.7.2016, sono decaduti da una dilazione già concessa, se la domanda viene presentata entro il 20.10.2016.
Si evidenzia che, nel sistema antecedente alle modifiche del DLgs. 159/2015, la decadenza dalla dilazione si sarebbe verificata con il mancato pagamento di otto rate, anche non consecutive. Attualmente, di contro, la decadenza si verifica con il mancato versamento di cinque rate, anche non consecutive.
Dovrebbe essere irrilevante, ai fini dell’accesso alla dilazione in esame, la tipologia di debito rateizzata; quindi, sempre che si tratti di decadenza da una dilazione concessa ai sensi dell’art. 19 del DPR 602/73 (in sostanza, di debiti iscritti a ruolo o derivanti da accertamenti “esecutivi”), rientrano nel beneficio, tra le altre, le rateazioni sia di tributi (IRPEF, IRES, IVA, imposta di registro, ICI, IMU, ecc.) che di contributi dovuti all’INPS o di premi INAIL.
3.1 PRESENTAZIONE DELLA DOMANDA
Per fruire della riammissione alla dilazione, i contribuenti devono presentare apposita domanda presso gli uffici di Equitalia, entro il 20.10.2016. A tal fine, Equitalia ha predisposto il modello “RR1”, scaricabile gratuitamente dal relativo sito Internet.
Per come è formulata la norma, non sembra necessario dimostrare lo stato di difficoltà finanziaria, quale che sia l’importo delle somme da dilazionare. Quindi, anche per gli importi superiori a 60.000,00 euro, la riammissione alla dilazione è automatica.
La domanda può essere presentata mediante consegna presso gli uffici di Equitalia oppure con il servizio postale. In quest’ultima eventualità, ai fini del rispetto del termine, per prudenza è bene prendere come riferimento la data di ricezione del plico ad opera dell’Agente della Riscossione.
3.2 NUOVO PIANO DI DILAZIONE
Il nuovo piano di dilazione può essere accordato per un massimo di 72 rate mensili, escludendo la possibilità di richiedere la c.d. “dilazione straordinaria” sino a 120 rate mensili.
Rimane comunque fermo l’eventuale maggior numero di rate concesso, se il contribuente fruiva già di una dilazione “straordinaria”. Sulla base delle indicazioni presenti nel sito Internet di Equitalia, i debitori che beneficiavano della dilazione “straordinaria” possono ottenere un numero di rate pari alla dilazione originaria.
Una volta ottenuto, il nuovo piano di dilazione non può essere prorogato, nemmeno in costanza di peggioramento dello stato di difficoltà finanziaria del debitore.
3.2.1 Effetti
Sulla base del dato normativo, la domanda per il nuovo piano di dilazione:
- inibisce l’adozione del fermo di beni mobili registrati e dell’ipoteca esattoriale, ferma restando la validità delle misure già disposte;
- osta all’avvio di nuove azioni esecutive.
Il pagamento della prima rata, comunque, sospende le esecuzioni in corso, salvo la presenza di atti espropriativi “irreversibili” (si pensi all’esito positivo dell’incanto o all’istanza di assegnazione).
Oltre a ciò, pagata la prima rata, il debitore dovrebbe poter ottenere il DURC e, come prevede l’art. 48bis del DPR 602/73, non dovrebbe più essere considerato inadempiente ai fini del “blocco” dei pagamenti delle Pubbliche Amministrazioni.
3.2.2 Decadenza
In relazione al nuovo piano di dilazione concesso ai sensi dell’art. 13bis co. 1 del DL 113/2016, conv. L. 160/2016, la decadenza dalla rateizzazione si verifica con il mancato pagamento di due rate, anche non consecutive.
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