Con il DL 23.10.2018 n. 119, pubblicato sulla G.U. 23.10.2018 n. 247, è stato emanato il c.d. “decreto fiscale collegato alla legge di bilancio 2019”.
Il DL 119/2018 è entrato in vigore il 24.10.2018, giorno successivo alla sua pubblicazione. Tuttavia, per numerose disposizioni sono previste specifiche decorrenze.
Di seguito si analizzano le novità in materia di “rottamazione dei ruoli” contenute negli artt. 3, 4 e 5 del suddetto DL 119/2018.
Il DL 119/2018 è in corso di conversione in legge e le relative disposizioni sono quindi suscettibili di modifiche ed integrazioni.
2 ASPETTI GENERALI DELLA NUOVA “ROTTAMAZIONE DEI RUOLI”
Per le “rottamazioni dei ruoli” previste dagli artt. 3 e 5 del DL 119/2018, se sussistono i requisiti indicati dalla norma, il contribuente, presentando apposita domanda entro il 30.4.2019, beneficia dello sgravio degli interessi di mora e delle sanzioni amministrative, principalmente di natura contributiva e tributaria.
Il carico potrà essere dilazionato in cinque anni, mediante rate scadenti il 31.7 e il 30.11 di ogni anno, a decorrere dal 31.7.2019. È anche possibile pagare in unica soluzione entro il 31.7.2019.
La nuova rottamazione è fruibile altresì dai contribuenti che, pur avendo aderito alle precedenti rottamazioni, non hanno perfezionato la procedura e intendono adesso accedere alla definizione secondo le nuove regole.
Annullamento delle “mini cartelle”
L’art. 4 del DL 119/2018 prevede inoltre l’annullamento delle c.d. “mini cartelle”, in relazione alle quali il debitore non deve fare nulla, essendo queste annullate d’ufficio dall’Agenzia delle Entrate-Riscossione se trattasi di ruoli consegnati nel periodo 1.1.2000-31.12.2010 e di importo fino a 1.000,00 euro, determinato in relazione a ciascun carico.
3 Requisiti per la nuova rottamazione
Al fine di beneficiare della nuova rottamazione dei ruoli e degli accertamenti esecutivi o avvisi di addebito, sono necessarie le seguenti condizioni:
- si deve trattare di carichi definibili, quindi non rientranti nelle esclusioni previste dal DL 119/2018 stesso;
- i carichi devono essere stati affidati all’Agenzia delle Entrate-Riscossione (ex Equitalia) dall’1.1.2000 al 31.12.2017;
- i debitori con carichi affidati dal 2000 al 2016 che, non avendo presentato la domanda entro il 21.4.2017, sono stati riammessi previa domanda presentata entro il 15.5.2018 ed hanno pagato entro il 31.7.2018 le rate scadute al 31.12.2016 relative a pregressi piani di rateazione, nonché i debitori con carichi affidati dall’1.1.2017 al 30.9.2017 che hanno presentato la domanda entro il 15.5.2018 senza poi pagare tutte o alcune rate, per poter beneficiare della presente rottamazione devono pagare le rate in scadenza a luglio, settembre e ottobre 2018 entro il 7.12.2018 in unica soluzione;
- se ci sono contenziosi in corso in merito ai carichi definibili, occorre impegnarsi a rinunciare ai medesimi nella domanda inviata all’Agenzia delle Entrate-Riscossione. Il giudice, dietro presentazione della domanda, sospende il giudizio.
Nozione di carichi affidati dall’1.1.2000 al 31.12.2017
Rientrano nella rottamazione, con le esclusioni di cui si dirà, tutti i carichi affidati agli agenti della riscossione nel lasso temporale compreso tra l’1.1.2000 e il 31.12.2017; siccome la norma fa riferimento all’affidamento del carico, non bisogna considerare la data di notifica della cartella di pagamento ma la data, antecedente, di consegna del ruolo, che non necessariamente coincide con il giorno in cui questo è stato reso esecutivo.
Nel caso degli accertamenti esecutivi e degli avvisi di addebito, invece, occorre considerare la data, successiva alla notifica di questi ultimi atti, di trasmissione del flusso di carico.
Gli agenti della riscossione forniscono, nell’area riservata del proprio sito o presso gli sportelli, ogni informazione utile.
3.1 Debitori che non hanno presentato domanda per le precedenti rottamazioni
I debitori che non hanno mai presentato domanda di rottamazione, possono beneficiare della nuova rottamazione di cui al DL 119/2018 senza condizioni particolari, presentando la domanda entro il 30.4.2019.
3.2 Debitori che hanno presentato la domanda di rottamazione in scadenza al 21.4.2017
I debitori che hanno presentato la domanda di rottamazione prevista dall’art. 6 del DL 193/2016:
- rispettando il termine del 21.4.2017, ma non hanno pagato in tutto o in parte l’importo dovuto (circostanze, entrambe, che causavano la decadenza dalla rottamazione),
- oppure oltre il termine del 21.4.2017 e che, per tale motivo, hanno ricevuto un diniego di definizione,
possono beneficiare della nuova rottamazione di cui al DL 119/2018 senza condizioni particolari, presentando la domanda entro il 30.4.2019.
3.3 Debitori riammessi per mancato pagamento delle rate di precedenti dilazioni scadute al 31.12.2016
I debitori che hanno inteso, inizialmente, fruire della rottamazione prevista dall’art. 6 del DL 193/2016, per accedere alla stessa avrebbero dovuto pagare le rate, relative a pregressi piani di dilazione in essere al 24.10.2016, in scadenza a ottobre, novembre e dicembre 2016.
L’inadempienza ha causato il mancato accesso alla rottamazione, ma, con l’art. 1 del DL 148/2017, il legislatore ha previsto una riammissione alla rottamazione, con domanda da presentare entro il 15.5.2018.
Per essere riammessi, i debitori avrebbero dovuto pagare, entro il 31.7.2018, le suddette rate, che l’Agenzia delle Entrate-Riscossione ha provveduto a liquidare.
3.3.1 Pagamento entro il 31.7.2018 delle rate di precedenti dilazioni
Se tali somme sono state pagate entro il 31.7.2018, e la totalità degli importi dovuti o la rata da rottamazione, a ottobre 2018, non può essere pagata o viene pagata in misura insufficiente, occorre, per fruire della nuova rottamazione, pagarla o integrare il pagamento entro il 7.12.2018.
In questa ipotesi, non è necessaria alcuna istanza per essere riammessi alla rottamazione e fruire della nuova dilazione del debito residuo in cinque anni: l’Agenzia delle Entrate-Riscossione liquiderà i nuovi importi d’ufficio entro il 30.6.2019.
Il debitore può comunque scegliere di pagare il debito residuo in unica soluzione entro il 31.7.2019.
Ove la rata di ottobre 2018 o la totalità delle somme non vengano versate entro il 7.12.2018, non è più possibile beneficiare della rottamazione (viene meno lo stralcio di sanzioni e interessi).
Rimane ferma la facoltà di pagare le rate secondo le scadenze della precedente rottamazione (31.10.2018, 30.11.2018 e 28.2.2019).
Chi, invece, nella domanda inviata entro il 15.5.2018, ha optato per il versamento in unica soluzione entro il 31.10.2018, sembra poter fruire della sola proroga al 7.12.2018.
3.3.2 Mancato pagamento entro il 31.7.2018 delle rate di precedenti dilazioni
Coloro che, entro il 31.7.2018, non hanno pagato le rate relative a pregressi piani di dilazione, accedono alla nuova rottamazione del DL 119/2018 senza problemi, presentando domanda entro il 30.4.2019.
3.4 Debitori che hanno presentato la domanda di rottamazione in scadenza al 15.5.2018 per carichi affidati dal 2000 al 2016
I debitori che hanno inteso, inizialmente, fruire della riammissione alla rottamazione prevista dall’art. 1 del DL 148/2017 (riservata a coloro che non avevano fatto domanda entro il 21.4.2017, ma l’hanno presentata entro il 15.5.2018), per accedere alla stessa avrebbero dovuto, entro il 31.7.2018, pagare le rate relative a pregressi piani di dilazione scadute al 31.12.2016, che venivano liquidate d’ufficio.
3.4.1 Pagamento entro il 31.7.2018 delle rate di precedenti dilazioni
Se le rate di precedenti dilazioni sono state pagate entro il 31.7.2018, e la totalità degli importi dovuti o la rata da rottamazione, a ottobre 2018, non può essere pagata o viene pagata in misura insufficiente, occorre, per fruire della nuova rottamazione, pagarla o integrare il pagamento entro il 7.12.2018.
In questa ipotesi, non è necessaria alcuna istanza per essere riammessi alla rottamazione e fruire della nuova dilazione del debito residuo in cinque anni: l’Agenzia delle Entrate-Riscossione liquiderà i nuovi importi d’ufficio entro il 30.6.2019.
Il debitore può comunque scegliere di pagare il debito residuo in unica soluzione entro il 31.7.2019.
Ove la rata di ottobre 2018 o la totalità delle somme non vengano versate entro il 7.12.2018, non è più possibile beneficiare della rottamazione (viene meno lo stralcio di sanzioni e interessi).
Rimane ferma la facoltà di pagare le rate secondo le scadenze della precedente rottamazione (31.10.2018, 30.11.2018 e 28.2.2019).
Chi, invece, nella domanda inviata entro il 15.5.2018, ha optato per il versamento in unica soluzione entro il 31.10.2018, sembra poter fruire della sola proroga al 7.12.2018.
3.4.2 Mancato pagamento entro il 31.7.2018 delle rate di precedenti dilazioni
Coloro che, entro il 31.7.2018, non hanno pagato le rate relative a pregressi piani di dilazione accedono alla nuova rottamazione del DL 119/2018 senza problemi, presentando domanda entro il 30.4.2019.
3.5 Rottamazione per i carichi affidati dall’1.1.2017 al 30.9.2017
Ai sensi dell’art. 1 del DL 148/2017, è stata prevista la possibilità di rottamare i carichi affidati dall’1.1.2017 al 30.9.2017, con presentazione della domanda entro il 15.5.2018 e versamento in unica soluzione entro il 31.7.2018, o in cinque rate (scadenti il 31.7.2018, 30.9.2018, 31.10.2018, 30.11.2018 e 28.2.2019).
Se le prime tre rate non sono state pagate o sono state pagate in misura insufficiente, occorre, per fruire della nuova rottamazione, pagarle per intero entro il 7.12.2018, utilizzando i bollettini precompilati già messi a disposizione dall’Agenzia delle Entrate-Riscossione.
In questa ipotesi, non è necessaria alcuna istanza per essere riammessi alla rottamazione e fruire della nuova dilazione del debito residuo in cinque anni: l’Agenzia delle Entrate-Riscossione liquiderà i nuovi importi d’ufficio entro il 30.6.2019.
Il debitore può comunque scegliere di pagare il debito residuo in unica soluzione entro il 31.7.2019.
Ove le rate di luglio, settembre e ottobre 2018, o la totalità delle somme, non vengano versate entro il 7.12.2018, non è più possibile beneficiare della rottamazione (viene meno lo stralcio di sanzioni e interessi).
Rimane ferma la facoltà di pagare le rate secondo le scadenze della precedente rottamazione (31.7.2018, 30.9.2018, 31.10.2018, 30.11.2018 e 28.2.2019).
Chi, invece, nella domanda inviata entro il 15.5.2018, ha optato per il versamento in unica soluzione entro il 31.7.2018, sembra poter fruire della sola proroga al 7.12.2018.
4 rottamazione parziale
Il debitore potrà decidere quali carichi definire, anche in relazione al singolo atto, dunque alla singola cartella di pagamento, avviso di accertamento esecutivo o avviso di addebito.
Quindi, ad esempio, se una cartella di pagamento porta a riscossione ruoli INPS e dell’Agenzia delle Entrate, è possibile sanare i soli ruoli INPS.
5 contenziosi in corso
La rottamazione non è preclusa dalla presenza di contenziosi relativi ai carichi che si vogliono definire, a condizione che nella domanda di rottamazione il debitore si impegni a rinunciare al giudizio in corso o a non presentare impugnazione avverso la sentenza.
6 esclusioni dalla rottamazione
Alcune fattispecie non sono incluse nella rottamazione. Si tratta dei seguenti casi:
- somme dovute a seguito di recupero di aiuti di Stato dichiarati incompatibili con la normativa dell’Unione Europea;
- crediti derivanti da pronunce della Corte dei Conti;
- multe, ammende e sanzioni pecuniarie dovute a seguito di provvedimenti e sentenze penali di condanna;
- sanzioni diverse da quelle irrogate per violazioni tributarie e/o contributive e/o relative ai premi dovuti agli enti previdenziali (si pensi alle sanzioni Antitrust, CONSOB, Banca d’Italia, al lavoro nero, al riciclaggio, alle sanzioni valutarie e così via);
- sanzioni amministrative per violazioni del Codice della strada.
Per queste ultime violazioni, la norma precisa che la rottamazione è possibile limitatamente agli interessi, quindi le sanzioni rimangono dovute (vengono meno, però, anche le maggiorazioni previste dall’art. 27 co. 6 della L. 689/81).
7 ambito applicativo della rottamazione
In presenza dei menzionati requisiti, tutti i ruoli consegnati agli agenti della riscossione, con le tassative esclusioni elencate in precedenza, possono rientrare nella rottamazione.
Non si tratta solo di qualsiasi imposta (IRPEF, IRES, IVA, addizionali, canone RAI, ecc.), dei contributi INPS e dei premi INAIL, ma di ogni entrata riscossa a mezzo ruolo.
Anche i contributi previdenziali dovuti alle Casse professionali rientrano nella rottamazione, nella misura in cui la riscossione sia affidata all’Agenzia delle Entrate-Riscossione o a Riscossione Sicilia SPA.
Non rientrano nella rottamazione le entrate locali (IMU, TARSU, ecc.) e le altre entrate (ad esempio, contributi previdenziali) se riscosse in proprio dagli enti creditori, o tramite affidamento ai propri concessionari locali (si pensi alla SORIS, per il Comune di Torino).
8 benefici della rottamazione
Il beneficio della rottamazione consiste nello sgravio:
- di qualsiasi sanzione amministrativa di natura tributaria o contributiva;
- degli interessi di mora, quindi unicamente degli interessi applicati dall’agente della riscossione se il debitore non ha onorato il debito nei termini a seguito di accertamento esecutivo, avviso di addebito o cartella di pagamento.
Sono pertanto dovute le somme a titolo di capitale e di interesse diverso da quello di mora.
Per fare un esempio, si pensi agli interessi da ritardata iscrizione a ruolo, irrogati unitamente agli avvisi di accertamento.
Del pari, rimangono dovuti per intero gli aggi o compensi di riscossione, calcolati però sugli importi effettivamente da corrispondere (quindi non sulle sanzioni amministrative).
9 Procedura di rottamazione
Il procedimento di rottamazione inizia con la domanda all’Agenzia delle Entrate-Riscossione, da inviare a pena di decadenza entro il 30.4.2019, con cui si indica la volontà di definire i ruoli indicati, la volontà di pagare in unica soluzione o tramite un massimo di dieci rate e ci si impegna a rinunciare ai contenziosi in corso.
A questo punto, se la totalità delle somme è versata per intero nel termine, oppure se le rate sono pagate nei termini e per l’esatto importo, la procedura si perfeziona. In presenza anche di un solo inadempimento, invece, la rottamazione non può ritenersi conclusa, con la conseguenza che:
- riemerge il debito a titolo di sanzioni amministrative e di interessi di mora;
- il carico non potrà essere oggetto di dilazione.
9.1 Effetti della domanda
Una volta presentata la domanda, l’Agenzia delle Entrate-Riscossione non può avviare azioni esecutive né disporre fermi amministrativi e ipoteche.
Rimangono però i fermi e le ipoteche già adottati alla data di presentazione della domanda; pertanto, se fosse già stata iscritta l’ipoteca esattoriale prima della presentazione della domanda, questa mantiene i suoi effetti e il titolo di prelazione.
Verosimilmente, dopo il pagamento della prima rata sarà possibile ottenere la sospensione del fermo.
Non possono proseguire le procedure esecutive immobiliari già avviate, salvo ci sia stato un incanto con esito positivo.
Nel momento in cui viene presentata la domanda, sono sospesi i termini di prescrizione e di decadenza relativi ai carichi definibili.
Sotto altro profilo, per effetto della presentazione della domanda si è considerati adempienti, tra l’altro, ai fini del c.d. “blocco dei pagamenti delle Pubbliche amministrazioni”. In conseguenza di ciò, si potranno riscuotere i crediti vantati nei confronti delle Pubbliche amministrazioni, che, ordinariamente, sono bloccati in presenza di ruoli e se di importo pari o superiore a 5.000,00 euro.
9.2 DURC, certificati di regolarità fiscale e rimborsi
Si ritiene che la presentazione della domanda di rottamazione determini il rilascio del DURC. Tale documento potrà essere annullato in caso di tardivo, insufficiente oppure omesso pagamento della totalità delle somme o di una rata del piano di dilazione.
Inoltre, la domanda di rottamazione dovrebbe essere condizione sufficiente sia per l’erogazione dei rimborsi (che non possono essere oggetto di fermo) sia per l’ottenimento dei certificati di regolarità fiscale, anche ai fini della partecipazione a gare di appalto.
9.3 Comunicazione dell’agente della riscossione
Entro il 30.6.2019, l’Agenzia delle Entrate-Riscossione comunica al debitore l’ammontare complessivo delle somme da pagare, nonché quello delle singole rate, unitamente al giorno di scadenza delle stesse.
10 versamento degli importi dovuti per la rottamazione
I versamenti degli importi dovuti per la rottamazione possono avvenire sia in unica soluzione sia in forma rateale.
Il pagamento in unica soluzione dovrà essere effettuato entro il 31.7.2019.
In caso di pagamenti rateali sono previste dieci rate di pari importo con scadenza al 31.7 e al 30.11 di ciascun anno con prima rata da pagare al 31.7.2019. Il debito può quindi essere spalmato dal 31.7.2019 al 30.11.2023.
Il pagamento della prima o unica rata delle somme dovute per la rottamazione determina l’estinzione delle procedure esecutive precedentemente avviate.
10.1 Modalità di pagamento
Il pagamento è eseguibile:
- tramite domiciliazione bancaria sul conto corrente indicato dal debitore nella domanda;
- oppure mediante i bollettini precompilati allegati alla comunicazione dell’Agenzia delle Entrate-Riscossione;
- oppure presso gli uffici dell’agente della riscossione, anche mediante compensazione dei crediti non prescritti, certi, liquidi ed esigibili vantati nei confronti delle Pubbliche amministrazioni.
È in ogni caso esclusa la compensazione nel modello F24, mediante crediti disponibili.
10.2 interessi di dilazione
Sugli importi dilazionati sono dovuti gli interessi:
- in misura pari al 2% annuo, a decorrere dall’1.8.2019, per i ruoli oggetto della nuova rottamazione;
- in misura pari allo 0,3% annuo, calcolati sempre a partire dall’1.8.2019, per i contribuenti che hanno aderito ad una precedente rottamazione e accedono alla nuova dilazione del debito residuo.
11 somme già pagate in precedenza
La presenza di pagamenti parziali non osta alla rottamazione. In nessun caso, però, il contribuente ha diritto al rimborso delle somme già pagate.
Quanto corrisposto a titolo di capitale e di interesse diverso da quello di mora e da dilazione dei ruoli, nonché a titolo di aggio e di rimborso delle spese di esecuzione, va invece scomputato dalle somme dovute per la rottamazione.
12 mancato perfezionamento della rottamazione
La rottamazione si perfeziona con il tempestivo e integrale pagamento, nei termini, della totalità degli importi dovuti o di tutte le rate. Pertanto, in caso di inadempimento viene meno lo stralcio delle sanzioni, degli interessi di mora e della relativa quota di aggi.
In presenza di inadempimenti nei versamenti, tutto il carico residuo, detratto quanto già versato, può essere escusso, ed è inibita una ulteriore dilazione dei ruoli.
Del pari, i termini di decadenza e di prescrizione per il recupero dei carichi di ruolo, che erano rimasti sospesi, riprendono a decorrere.
13 Risorse proprie dell’Unione europea e IVA all’importazione
Ai sensi dell’art. 5 del DL 119/2018, è possibile estinguere i debiti relativi ai carichi affidati agli agenti della riscossione, dall’1.1.2000 al 31.12.2017, a titolo di:
- risorse proprie tradizionali di cui all’art. 2 paragrafo 1 lett. a) delle decisioni comunitarie 2007/436/CE e 2014/335/UE (tra cui i dazi della tariffa doganale comune);
- IVA riscossa all’importazione.
Anche per questi ruoli, il beneficio della rottamazione è rappresentato dallo stralcio delle sanzioni e degli interessi di mora. Resta fermo l’obbligo del pagamento integrale dei tributi.
Per questi ruoli, il debitore deve inoltre corrispondere:
- dall’1.5.2016 al 31.7.2019, gli interessi di mora di cui all’art. 114 paragrafo 1 del regolamento comunitario 952/2013, fatto salvo quanto previsto ai paragrafi 3 e 4 dello stesso articolo 114;
- dall’1.8.2019, gli interessi al tasso del 2% annuo.
Sempre per questi tributi, non è possibile avvalersi della compensazione con crediti vantati nei confronti di Pubbliche amministrazioni.
La comunicazione di liquidazione degli importi, da parte dell’agente della riscossione, avviene entro il 31.7.2019.
Il pagamento della prima o unica rata scade il 30.9.2019, la seconda il 30.11.2019, e le restanti il 31.7 e il 30.11 di ciascun anno successivo, fino al 2023.
14 Stralcio dei ruoli sino a 1.000,00 euro
Con l’art. 3 del DL 119/2018 è stato previsto l’annullamento automatico dei ruoli affidati agli agenti della riscossione nel periodo compreso tra l’1.1.2000 e il 31.12.2010, di importo residuo fino a 1.000,00 euro.
Per il perfezionamento dell’annullamento:
- non è richiesta nessuna manifestazione di volontà da parte del beneficiario;
- l’agente della riscossione avrà tempo fino al 31.12.2018 per annullare i ruoli, ma gli effetti dell’annullamento si producono dal 24.10.2018, data di entrata in vigore della norma.
Considerato che la norma si riferisce specificamente agli “agenti della riscossione”, si ritiene che riguardi solo i debiti in carico all’Agenzia delle Entrate-Riscossione (ex Equitalia) e a Riscossione Sicilia SPA (considerato agente della riscossione dall’art. 3 del DL 203/2005). Sono quindi esclusi i debiti riscossi in proprio dai vari enti creditori (esempio, dai Comuni) e quelli affidati ai concessionari locali iscritti all’albo dell’art. 53 del DLgs. 446/97.
14.1 Ambito applicativo
Rientrano nell’annullamento automatico i debiti risultanti dai carichi affidati agli agenti della riscossione nel periodo 1.1.2000-31.12.2010, che risultino non pagati al 24.10.2018.
Siccome la norma fa riferimento all’affidamento del carico, non bisogna vagliare la data di notifica della cartella di pagamento ma la data, antecedente, di consegna del ruolo, che non necessariamente coincide con il giorno in cui questo è stato reso esecutivo.
L’importo del debito residuo al 24.10.2018 fino a 1.000,00 euro deve essere determinato in relazione al singolo carico comprensivo di capitale, interessi da ritardata iscrizione a ruolo e sanzioni, determinato al 24.10.2018.
Con le eccezioni di cui si dirà, rientrano nell’annullamento automatico tutte le tipologie di debiti, anche non di natura tributaria o contributiva.
La norma parla di debito residuo, quindi rientrano anche ruoli originariamente di importo maggiore se, al 24.10.2018, si rispetta il limite di 1.000,00 euro (si pensi, ad esempio, ad una intervenuta autotutela, o a sgravi derivanti da sentenze).
14.2 Nozione di singolo carico
Il limite di 1.000,00 euro deve essere determinato in relazione al singolo carico, dove per singolo carico si intende la partita di ruolo, come somma delle voci per capitale (esempio, imposta, contributo o altra entrata), sanzioni e interessi.
Ne consegue che ai fini dell’annullamento non sembra rilevare l’importo complessivo della cartella di pagamento, ma, in caso di pluralità di carichi iscritti a ruolo, l’importo di ciascuno.
14.3 Rilevanza del pagamento
Se il debitore ha pagato entro il 23.10.2018 il debito relativo ad un ruolo che rientra nell’ambito applicativo della norma, non avrà diritto al rimborso delle somme versate.
Ove, invece, il pagamento sia avvenuto dal 24.10.2018 in poi, avrà diritto al rimborso. In relazione a ciò, si potranno verificare due situazioni:
- se il beneficiario ha altri debiti, gli importi pagati e non dovuti verranno imputati al pagamento degli altri debiti;
- se il beneficiario non ha altri debiti avrà diritto al rimborso di tali importi. In tal caso, dovrebbe ricevere una comunicazione inviata dall’Agenzia delle Entrate-Riscossione con l’invito a ritirare il rimborso allo sportello o a comunicare le coordinate bancarie per riceverlo tramite bonifico.
14.4 Esclusioni
Sono escluse dall’annullamento automatico:
- le somme dovute a seguito di recupero di aiuti di Stato ai sensi dell’art. 16 del regolamento del Consiglio UE 13.7.2015 n. 1589;
- i crediti derivanti da pronunce della Corte dei Conti;
- le multe, ammende e sanzioni pecuniarie dovute a seguito di provvedimenti e sentenze penali di condanna;
- le risorse proprie tradizionali di cui all’articolo 2 paragrafo 1 lett. a) delle decisioni comunitarie 2007/436/CE e 2014/335/UE (tra cui i dazi della tariffa doganale comune);
- l’IVA riscossa all’importazione.
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Almanya’nın en iyi medyumu haluk hoca sayesinde sizlerde güven içerisinde çalışmalar yaptırabilirsiniz, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi medyumluk hizmeti sunuyoruz.
Almanya’nın en iyi medyumu haluk hoca sayesinde sizlerde güven içerisinde çalışmalar yaptırabilirsiniz, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi medyumluk hizmeti sunuyoruz.
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Almanya’nın en iyi medyumu haluk hoca sayesinde sizlerde güven içerisinde çalışmalar yaptırabilirsiniz, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi medyumluk hizmeti sunuyoruz.
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Almanya’nın en çok tercih edilen medyumu haluk yıldız hoca olarak bilinmektedir, 40 yıllık tecrübesi ile sizlere en iyi bağlama işlemini yapan ilk medyum hocadır.
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Merhaba Ben Haluk Hoca, Aslen Irak Asıllı Arap Hüseyin Efendinin Torunuyum. Yaklaşık İse 40 Yıldır Havas Ve Hüddam İlmi Üzerinde Sizlere 100 Sonuç Veren Garantili Çalışmalar Hazırlamaktayım, 1964 Yılında Irak’ın Basra Şehrinde Doğdum, Dedem Arap Hüseyin Efendiden El Aldım Ve Sizlere 1990 lı Yıllardan Bu Yana Medyum Hocalık Konularında Hizmet Veriyorum, 100 Sonuç Vermiş Olduğum Çalışmalar İse, Giden Eşleri Sevgilileri Geri Getirme, Aşk Bağlama, Aşık Etme, Kısmet Açma, Büyü Bozma Konularında Garantili Sonuçlar Veriyorum, Başta Almanya Fransa Hollanda Olmak Üzere Dünyanın Neresinde Olursanız Olun Hiç Çekinmeden Benimle İletişim Kurabilirsiniz.
Almanya’nın en iyi güvenilir medyumunun tüm sosyal medya hesaplarını sizlere paylaşıyoruz, güvenin ve kalitelin tek adresi olan medyum haluk hoca 40 yıllık uzmanlığı ile sizlerle.
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Dünyaca ünlü medyum haluk hocayı sizlere tanıtıyoruz anlatıyoruz, Avrupanın ilk ve tek medyum hocası 40 yıllık uzmanlık ve tecrübesi ile sizlerle.
Belçika’nın en iyi medyumu medyum haluk hoca ile sizlerde en iyi çalışmalara yakınsınız, hemen arayın farkı görün.
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Thanks , I’ve recently been looking for info about this topic for a while and yours is the greatest I’ve discovered so far. But, what in regards to the bottom line? Are you certain about the source?
Medyum haluk hoca avrupanın en güvenilir medyum hocasıdır, sizlerinde bilgiği gibi en iyi medyumu bulmak zordur, biz sizlere geldik.
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I could not resist commenting. Well written!
Ünlülerin tercih ettiği medyum hocamıza dilediğiniz zaman ulaşabilirsiniz, medyum haluk hocamız sizlerin daimi yanında olacaktır.
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Dünyaca ünlü medyum haluk hoca, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi hizmetleri vermeye devam ediyor, Aşk büyüsü bağlama büyüsü giden sevigiliyi geri getirme.
Medyum sitesi medyum hocamızın web sayfasını sizlere en iyi şekilde tanıtıyoruz, güzel yorumlarınız içinde teşekkkür ediyoruz.
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