Company and group taxation
The Firm provides tax advice to Italian and foreign companies for the solution of ordinary
(e.g. with regard to income taxation and VAT) and extraordinary fiscal matters (e.g. acquisitions, mergers, demergers,
contributions of assets, corporate restructurings) as well as advice for the preparation of financial statements, the application of national and international GAAP,
and connected tax compliance. The Firm carries out tax and accounting due diligence procedures and provides assistance in the negotiation and drafting of contracts with specific regard to tax and accounting aspects of acquisition and restructuring operations.
International and European taxation
Thanks to its wide experience in the field of international tax law, the Firm provides full assistance with regard to the tax aspects of Italian investments abroad and foreign investments in Italy (also by means of a large network of foreign correspondents in relation to foreign tax laws). The Firm analyses the issues concerning the application of Conventions against double taxation as well as the effects of the European law in the Italian tax law.
The Firm analyzes the problems relating to transfer pricing, performs the functional and risk analysis, identifying the transfer pricing method as well the relevant comparable transactions, and drafts the transfer pricing documentation. The Firm provides assistance with regard to international rulings as well as arbitration and mutual agreement proceedings.
Taxation of individuals
The Firm analyses the tax aspects of the transfer of residence of individuals into Italy and from Italy into a foreign country, the taxation of net worth and generational transfer as well as the taxation of financial income. The Firm also analyses the tax aspects of income realized in Italy by foreigners as well as of income realized abroad by Italians, their calculation and the connected tax compliance.
Pre-litigation and tax litigation
The Firm provides on a regular basis assistance in the litigation phase, drafting the defences and representing the taxpayer in the tax courts. Moreover, the Firm has developed a significant experience in the pre-litigation activity, providing assistance during tax audits and for the responses to invitations and questionnaires as well as with regard to out-of-court settlements. The Firm also assists the taxpayer in the tax ruling procedure and in the so-called “Voluntary Disclosure” procedure.
