41In the present case, even supposing that the application of Article 3(2bis)(b) of Decree-Law No 40/2010 may in a particular situation lead to an advantage for a beneficiary of that provision, it must be noted, with respect to the selectiveness of the measure, that it applies generally to all taxpayers who are parties to tax proceedings pending before the Corte suprema di cassazione, whatever the nature of the tax at issue, where those proceedings originate in an application at first instance made more than 10 years before the date of the entry into force of that provision and the tax authorities have been unsuccessful at first and second instance.
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