Tremonti Romagnoli Piccardi e Associati sent its comments to the Italian Tax Authority in the context of the public consultation on the draft Provision that establishes the procedure for the spontaneous re-payment of tax credits for research and development activities unduly used, specifically on the issue of access to the procedure in the case of already-challenged tax credits falling in part under one of the exclusion hypotheses provided for by law. These comments were incorporated into the final version published by the Italian Tax Authority on June 1, 2022.