What is derivation of liability and a succession?
The derivation of liability is the procedure initiated by the Administration to claim payment of outstanding debts and sanctions, be they tax and non-tax, from the persons or entities that the tax regulations hold liable as a consequence of having carried out certain actions or behaviours regulated in the Law.
If the proceedings end with a declaration of liability, the person liable shall be liable to pay the debts and sanctions, if any, for which he has been declared liable, together with the principal debtor.
The procedure against successors is the procedure used by the administration to demand payment of the debts and, where applicable, the outstanding sanctions of a deceased natural person or of a dissolved or liquidated entity from the heirs or from the participants, partners, co-owners or recipients of assets belonging to the entity, respectively.
If the deceased is a natural person, sanctions shall not be passed on under any circumstances.