Il trattamento fiscale ai fini della TARI per gli Enti Centrali della Chiesa Cattolica e per gli Enti gestiti direttamente dalla Santa Sede nella recente normativa e giurisprudenza nazionale

Abstract

The broad spectre of activities that can take place in properties owned by ecclesiastical entities raises questions of considerable systemic and tax relevance, closely related to the uncertainty surrounding the notion of ecclesiastical bodies. The latter, in fact, far from being circumscribed to the canonical system, indicates a category proper to the state system, concerning also non-Catholic religious entities. From a tax-law perspective, too, the subjective category of ecclesiastical entities unravels broadly; it does not identify a monolithic legal species of the subjective category of non-commercial entities under Article 73, paragraph 1 (c) of the t.u.i.r., as evidenced by the existence of a articulated and complex regulatory framework in force. With reference to this aspect, it looms interesting to examine the discipline concerning the waste tax for the central entities of the Catholic Church and those managed directly by the Holy See, in the light of concrete application and the related normative and jurisprudential evolution.