Quel che resta del dichiarativismo

The purpose of this essay is to provide the basis for updating the so called “teoria dichiarativa”. The starting point is that this theory – as well as its rival, i.e. the so called “teorica costitutiva” – cannot be conceived any more as a general theory neither of taxes, nor of their implementation models. In addition to this preliminary remark, it should be acknowledged that the administrative rules are an essential feature of the entire tax system. It is by having regards to these two assumptions that it is worthwhile to ask oneself what remains of the “teoria dichiarativa”