By the circular no. 65329 dated 8 June 2015, the Customs Agency clarified its position on the subject of preventive disputes, stating that even an assessment ex officio cannot be issued before 60 days from the date of the minutes where the issues were raised. This time limit, in fact, established in the taxpayer’s interest for setting out the reasons of defense and challenge of the mentioned issues,  must be complied with under penalty of nullity of the assessment either in case of an audit in the taxpayer’s premises or in case of an audit in the office.