Luca Petruzzella

│ PhD Candidate in Tax Law │
University of Bari Aldo Moro, Italy

I am a PhD Candidate in Tax Law at the University of Bari Aldo Moro and a trainee lawyer. My doctoral research investigates the intersection between artificial intelligence and tax collection. My broader interests include the Italian tax sanctions system and its relationship with the European ne bis in idem principle, as well as employment income taxation.

Below you can find my talks, publications, works in progress, institutional experience, and education.

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TALKS

1. Joint PhD Seminar – University of Innsbruck & University of Bari
16 May 2025
"Ne bis in idem: Between Punitive Powers and Fundamental Rights"An analysis of the evolving boundaries of the ne bis in idem principle in tax law, balancing state authority and taxpayer protection.____________________________
2. Lecture – Bar Association of Labour Consultants, Bari
19 June 2025
"The Reform of Self-Employment and Employment Income"An overview of recent legislative changes affecting the taxation of employment and self-employment income in Italy.____________________________
3. Summer School in European Environmental Taxation and Policies (UNIBA – UNINA)
7 November 2025
"Tax Expenditures and Circularity in the Agri-Food Sector"A discussion on how tax incentives can promote circular economy practices in the agricultural and food industry.____________________________
4. Conference "Taxpayer Rights and Guarantees: European Principles, National Reforms, New Technologies" – Catania
18 December 2025
"Ability to Pay and the Two-Year Preventive Agreement: Towards an AI-Driven Implementation?"An exploration of how artificial intelligence could enhance the assessment of taxable capacity in preventive tax agreements.

PUBLICATIONS

1. L. Petruzzella, "Banking Presumptions and the Non-Deductibility of Crime-Related Costs"
I Battelli del Reno, 20 May 2025
An analysis of the limits on cost deductibility when expenses are linked to criminal conduct under Italian tax law._____________________________
2. A.F. Uricchio – L. Petruzzella, "Article 21-bis of Legislative Decree 74/2000: Between Res Judicata and Evidentiary Value"
Il Processo, Issue 1/2025, pp. 294–312
A study on the interplay between criminal judgments and their evidentiary effects in tax proceedings._____________________________
3. L. Petruzzella, "Tax Penalties and Ne Bis In Idem: Compatibility Issues One Year After Legislative Decree 87/2024"
Unità e Pluralità del Sapere Giuridico, Issue 3/2025 (forthcoming)
An examination of the evolving relationship between tax sanctions and the European ne bis in idem principle after recent reforms._____________________________
4. L. Petruzzella, "Criminal Res Judicata in Tax Litigation: Open Questions"
Rivista di Scienza delle Finanze e di Diritto Finanziario, Issue 3/2025
A discussion of unresolved issues concerning the binding effect of criminal judgments in Italian tax disputes._____________________________
5. Aa. Vv., "Circularity Indicators for Agri-Food Enterprises: Towards a More Stable and Effective Tax Incentive System"
Diritto e Giurisprudenza Agraria, Alimentare e dell'Ambiente, Issue 6/2025
(Section authored: "Rethinking Agri-Food Tax Expenditures Between Ecological Transition and Intergenerational Solidarity")
A contribution on how to redesign tax incentives for the agri-food sector in light of circular economy principles and environmental sustainability.

WORK IN PROGRESS

1. "The Cost of Rights and the Sustainability of Taxation"
(Working paper)
A theoretical inquiry into the relationship between the protection of fundamental rights and the fiscal sustainability of the tax system.___________________________
2. "Active Surpluses Arising from Debt Discharge: Tax Implications"
(Working paper)
An analysis of the tax treatment of income arising from debt forgiveness under Italian law.___________________________
3. "Improper Tax Sanctions: Nature, Limits, and Constitutional Issues"
(Working paper)
A study on non-punitive measures that produce sanctioning effects in tax law, questioning their compatibility with fundamental guarantees.___________________________
4. "The Two-Year Preventive Tax Agreement: Critical Aspects and Open Questions"
(Working paper)
An examination of the new cooperative compliance tool (concordato preventivo biennale) and its implications for taxpayers and tax authorities.
___________________________

EDUCATION

Master's Degree in Law (Laurea Magistrale in Giurisprudenza)
2020 – 2025 | University of Bari Aldo Moro
Final grade: 110/110 with Honours (summa cum laude), with special commendation for academic excellence and invitation to pursue further studies. GPA: 30/30 (20 out of 30 exams passed with distinction).Bar School (Scuola Forense)
2025 – present
Classical High School Diploma (Diploma di Maturità Classica)
2015 – 2020 | Liceo Classico Leonardo da Vinci, Molfetta
Final grade: 100/100 with Honours.

AWARDS & SCHOLARSHIPS
"Pantaleo Carabellese" National Scholarship (2021)
First Prize – Snacknews Contest (Corriere della Sera & Bocconi University, 2019)"Nicola Annese" Scholarship – For academic merit and consistently outstanding performance throughout high school (2019)"Corrado Poli" Scholarship – For academic achievement and commitment to civic participation and citizenship values (2019)"Regione Puglia – Aldo Moro" Scholarship (2019)"Associazione Diplomatici" Scholarship (2019)