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The MOG 231 Exemption Model

Under D.Lgs 231/2001, companies are liable for customs fraud committed by management. The only legal defence (esimente) is the prior adoption of an effective organizational model. We map your customs risks to build this shield.

1. Risk Mapping

Identifying sensitive activities: Broker selection, Origin declaration, Value definition.

2. Protocol Design

Drafting SOPs with "Segregation of Duties" to prevent autonomous fraud.

3. Vigilance (OdV)

Establishing information flows to the Supervisory Body to prove control.

Litigation Defence Strategy

When an audit begins, the timeline is critical. As Tax Litigation Specialists, we intervene immediately:

Phase 1: Administrative (PVC)

Drafting "Technical Observations" within 60 days of the Audit Report (PVC). This is the most effective phase to annul findings before they become assessments[cite: 202].

Phase 2: Judicial (Tax Court)

Full representation before Provincial and Regional Tax Courts. Management of telematic filings and oral hearings for complex TP/Customs disputes[cite: 202].