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Reviews & Ratings
It is a new approach that focuses on the most important elements of the dispute, it proposes an amicable settlement mode of cooperative style, aiming first to identify the mutual interests for a consensual solution. This non-jurisdictional dispute resolution practice is evolving very rapidly.
It has given rise to an exciting debate within public law theory, both in terms of substance and form. Specialists have debated the various legal possibilities of integrating it into procedures and testing its compatibility with the tax system.
In the end, the practice that was accepted by the DGI is that of negotiated settlement of the dispute, leading to a transaction. .
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