On the use of "data" in defining new taxable events bases and in the different determination of tax bases connceted to traditional taxable events

The paper analyzes the use of data in defining new taxable events and tax base methods in the context of the digitalization of the Italian tax administration. Digital data is changing the definition of traditional taxable entities and tax bases. Recent regulatory interventions have created extraordinary taxes and new taxation methods based on unconventional digital and economic indicators. The constitutional legitimacy of taxing based on non-financial elements such as environmental data or potential economic value is under discussion. This opens the possibility of revising the principle of ability to pay, linking it to elements of substantive fairness rather than solely to financial capacity.