Il processo tributario tra modello impugnatorio e modello dichiarativo

In the first part of the paper, it is argued that, within the Italian Supreme Court, two models of tax litigation coexist: the annulment action and the declaratory action (or action for a negative declaratory judgment). After having indicated the main characteristics of the two models, the paper analyzes their consequences, focusing on the manifestations of the declaratory model that have been abandoned by recent case law