La natura giuridica dell’atto di accertamento e il contraddittorio nel pensiero di Dino Jarach: spunti per una riflessione sull’attuale ordinamento

This article examines the theories of Dino Jarach on the legal nature of the tax assessment notice exposed in his "El hecho imponible. Teoria general del derecho tributario sustantivo" book. In the Italian legal system, there are many problems concerning the tax assessment procedure that must be resolved. Dino Jarach's theories are still relevant today and can constitute a valid starting point for an organic reform of this procedure. First of all, in a reform perspective, it is necessary to correctly focus the nature and the task of the task assessment activity. Secondly, it is necessary to develop a regulatory framework that allow for an efficient and effective dialogue between the tax administration and the taxpayer.