Article 4 of Law No. 55-A/2012, of 29 October, added article 28 to the TGIS. This provision foresees the taxation of property rights, usufruct and the right to surface on urban real estate, with tax value equal to or greater than one million euros for the purposes of IMI. This new tax gave rise to several complaints to the Ombudsman. Several enquiries were then made with the tax authorities and the State Secretary for Tax Affairs but replies were unable to clarify all issues raised. Following the intention expressed by the XXI Constitutional Government to review the existing legal framework, with the aim of eliminating the pernicious effects of its less correct and reasonable implementation, the Ombudsman deemed as appropriate to bring to the attention of the new State Secretary for Tax Affairs his thoughts on the subject, in order to contribute to the improvement and clarification of the legal system in question, having in consideration the position of the Constitutional Court established in the decision No. 620/2015, of 31 December 2015 and in the decision No. 692/2015, of 16 December 2015. On the other hand, and in relation to the loss of exemption of Municipal Real Estate Tax (IMI) for low-tax value real estate, owned by low-income taxpayers, the Ombudsman has requested the State Secretary for Tax Affairs a significant update of the maximum limits, foreseen in article 11-A of the CIMI, to the total gross household income and to the overall tax value of all real estate belonging to the household, in order to ensure the respect for constitutional imperatives of the right to housing and the right to private property. The State Secretary for Tax Affairs informed the Ombudsman that the draft State budget for 2017 included a provision revoking article 28 of the TGIS. For having left out all other questions and comments contained in the communication, the Ombudsman has made a remark. • Case Q-3821/15 Entity addressed: Tax Justice Department of Tax and Customs Authority. Date: 2016.04.06 Subject: Tax. Penalties. Communication of invoices to the Tax and Customs Authority Sequence: Suggestion expressly and fully accepted | 119