I redditi da attività agricole connesse: per una lettura del requisito della prevalenza in termini anche qualitativi

Abstract

Defining the “prevalence” of traditional agricultural activities over other agricultural related activities is a central issue in the legal and tax frameworks of agricultural businesses. In the tax domain, and in specific regard to the general personal income tax known as IRPEF in Italy, the approach adopted by the tax authority and case law is quantitative: depending on the type of activity, prevalence is measured using either the volumes or the value/cost of the products processed, or else the income generated by the agricultural-related activity. However, considering that agriculture related activities represent a form of modernization and evolution of traditional agricultural activities, qualitative aspects should be also considered for determining prevalence.