Studio Legale Pistone

SUBORDINAZIONE E AGENZIA

Quando il rapporto di agenzia simula un rapporto di lavoro subordinato e spettanza delle differenze retributive

La giurisprudenza in più occasioni ha fatto applicazione dei principi generali in materia di lavoro subordinato per distinguerlo dal rapporto di agenzia, avente natura parasubordinata e che prevede espressamente la sottoposizione dell’agente a direttive ed istruzioni.

In particolare, ha evidenziato che la presenza in un rapporto di indici quali:

  • la collaborazione 
  • l’assenza nel lavoratore del rischio economico 
  • la continuità della prestazione 
  • la predeterminazione della retribuzione 
  • l’obbligo di osservanza di un determinato orario, 
  • l’alienità dei mezzi di produzione, 

possono avere un rilievo distintivo soltanto complementare e secondario e divengono non determinanti se non accompagnati dal requisito della subordinazione, intesa quale vincolo di natura personale che assoggetta il prestatore d’opera al potere direttivo, organizzativo e disciplinare del datore di lavoro con conseguente limitazione della sua libertà.

Per ritenere, dunque, sussistente la subordinazione è necessario accertare che la prestazione d’opera sia regolata nel suo svolgimento e che, quindi, il potere direttivo del datore di lavoro inerisca all’intrinseco svolgimento della prestazione lavorativa poiché solo in questi casi il vincolo si traduce in limitazione significativa della libertà del prestatore d’opera, che generalmente si ritiene valga ad evidenziare e caratterizzare la natura subordinata del rapporto di lavoro, che non è presunta dalla legge, ma deve essere dimostrata da chi la deduce con il riscontro in concreto del sopra specificato requisito della subordinazione.

Ma una volta dimostrato, a seguito di accertamento giudiziale, che un agente doveva essere in realtà inquadrato come lavoratore subordinato, quali rivendicazioni retributive devono essere considerate?

La risposta della giurisprudenza è chiara.

La retribuzione spettante al lavoratore subordinato, fittiziamente inquadrato come agente, deve essere stabilita sulla base del criterio dell’assorbimento, e non di quello del cumulo dei compensi pattuiti e dei minimi previsti dalla contrattazione collettiva. Pertanto, nel caso in cui risulti accertato in sede giudiziale che tar le parti è intercorso un rapporto di lavoro subordinato, e non un rapporto di agenzia, in contrasto con la sua qualificazione negoziale, e quindi sia riconosciuto al dipendente il trattamento retributivo previsto dai contratti collettivi per l’intera durata del rapporto di lavoro, occorre porre a confronto il trattamento economico percepito dal lavoratore in base al contratto di agenzia e quello che gli sarebbe spettato secondo le previsioni dell’invocata contrattazione collettiva, ai fini della individuazione del trattamento complessivamente più favorevole.

Pertanto, in concreto, se il lavoratore ha percepito a titolo di provvigioni, premi e benefit, un importo pari al trattamento globale spettante sulla base dei minimi tabellari di cui al contratto collettivo nazionale, nulla sarà dovuto al predetto lavoratore a titolo di differenze retributive.

Guarda anche l’articolo: “Perché rivolgersi ad un Avvocato specializzato in contratto di agenzia”, qui  


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