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231: la frode IVA entra nell’elenco dei reati presupposto

Dichiarazione fraudolenta, Decreto Legislativo 231/2001

Nella Gazzetta Ufficiale n. 252 del 26 ottobre 2019 è stato pubblicato il Decreto Legge 26 ottobre 2019, n. 124, recante “Disposizioni urgenti in materia fiscale e per esigenze indifferibili” (il “Decreto Fiscale”), che introduce il reato di dichiarazione fraudolenta mediante uso di fatture o altri documenti per operazioni inesistenti nel catalogo dei reati presupposto rilevante al fine di configurare la responsabilità amministrativa delle persone giuridiche ai sensi del Decreto Legislativo n. 231 del 2001.

L’art. 39, comma 2, del Decreto Fiscale introduce infatti nel Decreto 231 il nuovo articolo 25-quinquiesdecies, rubricato “Reati tributari”, che dispone quanto segue: “In relazione alla commissione del delitto di dichiarazione fraudolenta mediante uso di fatture o altri documenti per operazioni inesistenti previsto dall’articolo 2 del decreto legislativo 10 marzo 2000, n. 74, si applica all’ente la sanzione pecuniaria fino a cinquecento quote”.

La nuova previsione normativa entrerà in vigore dalla data di pubblicazione nella Gazzetta Ufficiale della legge di conversione del Decreto Fiscale.

Il reato di dichiarazione fraudolenta mediante uso di fatture o altri documenti per operazioni inesistenti è previsto dall’art. 2 del Decreto Legislativo n. 74 del 2000, a norma del quale “E’ punito con la reclusione da quattro a otto anni chiunque, al fine di evadere le imposte sui redditi o sul valore aggiunto, avvalendosi di fatture o altri documenti per operazioni inesistenti, indica in una delle dichiarazioni annuali relative a dette imposte elementi passivi fittizi. Il fatto si considera commesso avvalendosi di fatture o altri documenti per operazioni inesistenti quando tali fatture o documenti sono registrati nelle scritture contabili obbligatorie, o sono detenuti a fine di prova nei confronti dell’amministrazione finanziaria”.

Si evidenzia che, secondo la definizione prevista dall’art. 1 D. Lgs. n. 74/2000, “per <fatture per operazioni inesistenti> si intendono le fatture o gli altri documenti aventi rilievo probatorio analogo in base alle norme tributarie, emessi a fronte di operazioni non realmente effettuate in tutto o in parte o che indicano i corrispettivi o l’imposta sul valore aggiunto in misura superiore a quella reale, ovvero che riferiscono l’operazione a soggetti diversi da quelli effettivi”.

Frodi in materia di Iva e Decreto Legislativo 231/2001

Nella Gazzetta Ufficiale n. 245 del 18 ottobre 2019 è stata pubblicata la Legge 4 ottobre 2019 n. 117, in vigore dal 2 novembre, con la delega al Governo per recepire la Direttiva (UE) 2017/1371 “relativa alla lotta contro la frode che lede gli interessi finanziari dell’Unione mediante il diritto penale” (“Direttiva PIF”) (“Legge di delegazione europea 2018”).

Ai sensi dell’art. 3, comma 1, lettera e), della Legge di delegazione europea 2018 il Governo dovrà integrare le disposizioni del Decreto 231 prevedendo espressamente la responsabilità amministrativa da reato delle persone giuridiche anche per le “gravi” frodi in materia IVA, laddove il concetto di gravità è definito avendo riguardo al carattere transfrontaliero delle condotte illecite (“connessa a due o più Stati membri”) e all’elevato ammontare del danno complessivo (“almeno pari a dieci milioni di euro”).

Oltre alle sanzioni amministrative, il Governo dovrà introdurre nel Decreto 231 anche le sanzioni previste dall’articolo 9 della Direttiva PIF, che comprendono l’esclusione dal godimento di un beneficio o di un aiuto pubblico, l’esclusione temporanea o permanente dalle procedure di gara pubblica, l’interdizione temporanea o permanente di esercitare un’attività commerciale, l’assoggettamento a sorveglianza giudiziaria, l’applicazione di provvedimenti giudiziari di scioglimento e la chiusura temporanea o permanente degli stabilimenti che sono stati usati per commettere il reato, con la precisazione che tutte le sanzioni dovranno essere “effettive, proporzionate e dissuasive”.

Rilevante è dunque l’impatto che tali novità normative avranno sui modelli organizzativi 231. Le società saranno chiamate ad aggiornare il proprio assetto organizzativo identificando e analizzando tutti i rischi fiscali connessi alla propria attività al fine di predisporre adeguati sistemi di gestione.

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