Preventive seizure of the entire AM Distribution srl business complex and two properties between Casalnuovo and Naples: Nola investigating judge Raffaele Muzzica granted the prosecutor's request, deeming the risk of the alleged conduct continuing to be "present" and the connection between company assets and the alleged tax crimes "concrete."
At the center of the investigation is Angelo Napolitano, the company's legal representative, who is under investigation for fraudulent tax returns using other means relating to the 2023 and 2024 VAT years, resulting in a total VAT evasion of €5.740.561.
The preliminary investigations judge's order
The decree was issued by the Court of Nola, GIP/GUP section, within the scope of the proceedings indicated in the epigraph, and provides for a preventive "preventive" seizure pursuant to Article 321 of the Criminal Code.
The restriction applies to the company's assets, including "appurtenances and equipment," including the properties indicated in the provision, but excluding consumer electronics belonging to third parties.
VAT fraud hypothesis: reverse charge and "black" sales
According to the reconstruction cited by the investigating judge, the company allegedly used reverse charge invoices to entities deemed to be "shell companies" or otherwise facing serious tax liabilities to justify the removal of goods from the warehouse without applying VAT, while the goods were intended (at least in part) for retail sales to private individuals.
The investigations (by the Guardia di Finanza, wiretaps, searches, and computer analysis) have revealed two leads: below-cost prices and insistent requests for cash payments, with transactions "disguised" for tax purposes through sham invoicing using reverse charge.
The disputed numbers: 2023 and 2024
For the 2023 tax year, the decree indicates an undisclosed VAT payable of €1.777.976, attributed to undeclared sales disguised as reverse charge invoices.
For the 2024 tax year, the disputed amount rises to €3.962.585, bringing the total VAT evasion to €5.740.561, calculated by applying the 22% rate to assets reconstructed using management data and the difference between non-tax and tax documents.
The “current danger”: social videos and the alleged continuation
The investigating judge highlights, for the periculum in mora, a subsequent judicial police note (September 2025) which describes the alleged continuation of the same scheme even after searches and a previous seizure.
The decree cites videos posted on TikTok in which Napolitano continues to promote smartphones and hi-tech products at prices well below average, accompanying the offers with calls for cash payments using coded expressions ("Avellino T-shirts," "croccantini," "pappardelle," "peghegne").
Companies under scrutiny and invoices following the first seizure
Among the economic entities mentioned in the decree are Tecno Group srl and Sparrow Industries Srl, indicated as recipients of reverse charge invoices despite poor operational profiles or anomalies (absence of employees, omitted payments/declarations, headquarters in a private residence, etc.).
The ruling also highlights the issuance of invoices after the first seizure, a factor that, according to the judge, reinforces the idea of the operational continuity of the circuit deemed illicit.
What was seized
Preliminary Investigating Judge Raffaele Muzzica has ordered the precautionary seizure of the business assets of AM Distribution srl and Napolitano Angelo, including two properties: one in Casalnuovo di Napoli (Via Napoli no. 159) and one in Naples (Corso Garibaldi no. 231).
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Comments (1)
It's interesting to read about these investigations, but I don't understand how so many anomalies and frauds can occur without anyone noticing them first. I wonder what checks are carried out on companies to prevent such situations.