Competencies
Taxation of companies and corporate groups
The Firm assists clients in all their needs in the area of direct and indirect taxation, in relation to ordinary business activities, and oversees their compliance with tax obligations.
The followings aspects are especially relevant in this area:
- assistance in the calculation of income taxes and in the preparation of tax returns;
- drafting of expert opinions on complex direct or indirect tax matters.
In addition, the Firm’s professionals have significant experience in the field of Italian and international accounting standards.
M&A and corporate reorganizations
The Firm assists companies and corporate groups in the planning and implementation of corporate transactions (mergers, demergers, transfers or sales of businesses or shareholdings), with specific focus on the optimization of the associated taxation.
The Firm’s activity in this area includes:
- assistance in structuring acquisition transactions or transactions to be carried out as part of the reorganization process;
- execution of tax due diligence;
- submission to the Italian Revenue Agency of requests for preliminary ruling to ensure the tax treatment applicable to the reorganization process or the acquisition is known in advance.
Taxation of financial instruments
The Firm provides advice to individuals in relation to the tax aspects of their financial investments.
The Firm also provides advice to Italian and foreign UCITS, Real Estate Investment Funds and Private Equity Funds.
The Firm’s activity in this area includes:
- taxation of Italian and foreign financial investments by individuals;
- taxation of Collective Investment Undertakings: Italian and foreign mutual investment funds, SICAVs, SICAFs, Italian and foreign real estate investment funds;
- taxation of unit-linked insurance policies.
Capital market transactions and ordinary and special corporate finance transactions
The Firm provides tax advice on all the main categories of capital market transactions, including issues and placements of stocks, bonds and structured securities, both on regulated markets and through private placements.
The Firm also provides advice to both financial intermediaries and companies on the taxation of ordinary and special corporate finance transactions, such as the provision of loans, the implementation of structured finance transactions, securitization and factoring.
Asset tax optimization, generational transition planning, asset protection
The Firm advises its clients in relation to the tax aspects that affect high net-worth individuals and the management, protection and generational transfer of their assets.
In this area the Firm offers the following services:
- tax optimization for personal and family assets;
- inheritance tax optimization;
- consulting in the formation of trusts and family trust funds and related tax optimization.
International Taxation
The Firm provides advice to Italian and foreign corporate groups in all aspects of international, direct and indirect taxation.
Including:
- choosing a legal structure for foreign operations: branch or subsidiary;
- calculating the income of Italian permanent establishments of foreign companies or of foreign permanent establishments of Italian companies;
- defining the transfer pricing policy of corporate groups and preparing the related transfer pricing documentation;
- analysis and interpretation of tax treaties;
- submission to the Italian Revenue Agency of requests for preliminary rulings on transfer prices and/or other aspects of international operations of companies and corporate groups;
- submitting applications for the waiver of CFC regulations;
- planning and executing cross-border corporate transactions (mergers, demergers, transfers) and defining the related tax treatment;
- planning and implementing the transfer of the company registered office from abroad to Italy and vice versa and defining the related tax treatment;
- assisting companies in pre-litigation and litigation concerning international tax issues.
To perform the above services the Firm may take advantage of a network of independent foreign correspondents carefully selected and with proven professional qualifications.
Tax litigation and pre-litigation
The Firm provides assistance in every stage of tax pre-litigation and litigation.
In this area the Firm:
- assists individuals and companies during tax audits by the Italian Tax Police or the Italian Revenue Agency, handling interactions with the tax inspectors and preparing defence statements;
- prepares supporting documents for any out-of-court settlement of tax disputes and assists its clients in relations with the Italian Revenue Agency;
- represents individuals and businesses before tax courts at each stage of the proceedings.