<s>[INST] The next text is a question of a member of the European parliament:"Under Italian Law No122 of 30July2010, from 2011 onwards, assessment notices for income tax, IRAP [Italian regional corporate tax] and VAT issued by the Revenue Office are immediately enforceable: assessment notices are enforceable without the infamous recovery notice, as the main Italian collection agency is entitled to make them subject to immediate enforcement proceedings. This procedure, which is absolutely detrimental to the taxpayer, was ‘attenuated’ by the provisions of Articles29-30 of the so-called Development Decree-Law (Decree-Law No70 of 13May2011). These rules, in fact, reintroduce abhorrent harassment of Italian citizens by the State, using the solve et repete, or ‘pay first and then claim’ principle of taxation. As a contractual clause, solve et repete is considered legitimate, since the parties are free to agree that the debtor in a contractual relationship should first pay up and then take out a case. However, in tax law, the principle is to be considered illegitimate, as public administrations and citizens are not on the same level — forcing citizens to pay a debt that has still to be proven, without their having previously expressed willingness to pay first and then claim, violates their right to defend themselves and to keep hold of the goods which are the subject of a debt that is ‘unenforceable’, since it is not yet objective and proven. The Italian Constitutional Court declared solve et repete illegal in 1961 under Ruling No21/1961, thus wiping it from the Italian tax code and confirming the rejection of a measure that adversely affects not only assets but also the personal sphere (given the value that property has in everyone’s life).  Given that:      —  the requirements for applying for a European order for payment are comprehensively governed by EClaw and that States cannot therefore introduce additional requirements (judgment of the European Court of Justice (First Chamber) of 13December2012 in CaseC-215/11); therefore, even in terms of European legislation solve et repete taxation is in stark contrast to the principle of equality among citizens, the right to take legal action to protect one’s rights and the inadmissibility of limiting said right, including the protection of the citizen in claiming damages against the State,    does the Commission regard it as permissible to extend the parameters of illegitimacy to include an infringement of the EU’s principle of due process, where fairness of proceedings and equality of arms are expected between ‘prosecution’ and ‘defence’ (given that solve et repete inverts the natural order between assessment and payment of the debt and places the burden of proof upon the debtor)?"
Analyze carefully the text and assign it to the most relevant policy area among those listed below. Do not explain your answer and return only a number.
Policy area numbers: 1 = Macroeconomics
2 = Civil Rights, Minority Issues and Civil Liberties
3 = Health
4 = Agriculture and Fisheries
5 = Labour, employment and pensions
6 = Education
7 = Environment
8 = Energy
9 = Immigration
10 = Transportation
12 = Law and Crime
13 = Social welfare
14 = Regional and Urban issues and Planning
15 = Banking, finance and domestic commerce issues
16 = Defence
17 = Space, science, technology, and communications issues
18 = Foreign trade
19 = International affairs and foreign aid
20 = Governance and government
21 = Public Lands, Water Management and Territorial Issues
23 = Culture and media
[/INST]. Answer = [1]. </s>
Under Italian Law No122 of 30July2010, from 2011 onwards, assessment notices for income tax, IRAP [Italian regional corporate tax] and VAT issued by the Revenue Office are immediately enforceable: assessment notices are enforceable without the infamous recovery notice, as the main Italian collection agency is entitled to make them subject to immediate enforcement proceedings. This procedure, which is absolutely detrimental to the taxpayer, was ‘attenuated’ by the provisions of Articles29-30 of the so-called Development Decree-Law (Decree-Law No70 of 13May2011). These rules, in fact, reintroduce abhorrent harassment of Italian citizens by the State, using the solve et repete, or ‘pay first and then claim’ principle of taxation. As a contractual clause, solve et repete is considered legitimate, since the parties are free to agree that the debtor in a contractual relationship should first pay up and then take out a case. However, in tax law, the principle is to be considered illegitimate, as public administrations and citizens are not on the same level — forcing citizens to pay a debt that has still to be proven, without their having previously expressed willingness to pay first and then claim, violates their right to defend themselves and to keep hold of the goods which are the subject of a debt that is ‘unenforceable’, since it is not yet objective and proven. The Italian Constitutional Court declared solve et repete illegal in 1961 under Ruling No21/1961, thus wiping it from the Italian tax code and confirming the rejection of a measure that adversely affects not only assets but also the personal sphere (given the value that property has in everyone’s life).  Given that:      —  the requirements for applying for a European order for payment are comprehensively governed by EClaw and that States cannot therefore introduce additional requirements (judgment of the European Court of Justice (First Chamber) of 13December2012 in CaseC-215/11); therefore, even in terms of European legislation solve et repete taxation is in stark contrast to the principle of equality among citizens, the right to take legal action to protect one’s rights and the inadmissibility of limiting said right, including the protection of the citizen in claiming damages against the State,    does the Commission regard it as permissible to extend the parameters of illegitimacy to include an infringement of the EU’s principle of due process, where fairness of proceedings and equality of arms are expected between ‘prosecution’ and ‘defence’ (given that solve et repete inverts the natural order between assessment and payment of the debt and places the burden of proof upon the debtor)?