We offer specialized advice and legal assistance in domestic and international tax matters to leading Italian and multinational clients. We have active participation in study groups, advisory committees and commissions both nationally and internationally. The active role of our tax professionals in international professional organisations (such as e.g. IBA, IFA, etc.) enables the required constant essential updating ensuring a high level of specialization. Close interrelationship with the professionals of the other departments of the firm ensures an interdisciplinary approach to tax matters.
Corporate Taxation
We assist our clients in the handling of recurrent (day-to-day) and extraordinary corporate tax issues.
Taxation of extraordinary transactions
We have structured numerous extraordinary transactions (mergers, demergers, etc.) aimed in the acquisition of enterprises, companies or groups of companies, structuring original acquisition solutions by assisting clients and colleagues in the negotiation of the respective contracts, with particular reference to the tax implications.
International taxation
We are highly specialized in international tax matters, with particular focus on international tax planning and advice on the interpretation of double taxation treaties and European regulations. We are constantly involved in the discussions and negotiations about interpretative international guidance (such as OECD, G20, etc.).
Transfer pricing and unilateral and multilateral procedures for international tax dispute resolution
We have developed specific expertise both in preparing the transfer pricing documentation, as well as in the structuring and identification of the best arm’s length pricing method among the traditional and alternative methods. We have many years of experience in negotiating Advanced Pricing Arrangements with the relevant competent authorities and we are leaders in dealing with MAP and EU arbitration procedures for double taxation cases.
Corporate Group Taxation
We assist in the implementation of efficient tax strategies, management of corporate group reorganization transactions, as well as post-acquisition integration transactions of legal entities.
Taxation of financial instruments and funding
We advise on the tax implications of innovative financial products as well as to those relating to structured finance transactions, with particular reference securitization of receivables. We also have significant experience in analyzing the taxation of short and medium to long-term funding granted by national and international entities, as well as in the tax-efficient structuring of related guarantee packages.
Taxation of renewable energy
We have considerable expertise in tax issues related to investments in the production of energy from renewable sources; considerable experience has also been gained in connection with the ordinary taxation of renewable energy companies about the taxation of both incentives provided in relation to the production and sale of energy produced and energy trading activities.
Taxation of private equity funds and real estate funds
We provide highly qualified tax advice in connection with the tax aspects concerning the establishment of private equity and real estate investment funds, the tax regime of Italian and foreign investors, the structuring of domestic and cross-border investments, as well as assistance in complex tax audits by Italian tax authorities and settlement procedures.
Real Estate Taxation
We have gained relevant experience in real estate taxation, from the structuring of acquisition and financing transactions of real estate portfolios, to addressing ordinary issues such as the VAT and indirect tax regime.
VAT and indirect taxes
We specialize in offering advice on VAT, in identifying the correct tax treatment of intra-community and international transactions, as well as on issues related to excluded and tax-exempt transactions. We have, in addition, considerable experience in customs and excise duties, including those on energy products, registration tax and stamp duty.
Taxation of private clients, high-net-worth individuals and families
We assist our private clients in organizing tax-efficient structures for the management and transfer of family assets. We have become familiar with the use of sophisticated financial and insurance products as well as the use of trusts and foundations.
Compensation and incentive plans
We have developed interdisciplinary tax and labour law expertise in employment income taxation, with particular focus on incentive structures involving fringe benefits, stock option plans and pension plans, as well as programs related to business mergers or transfers.
Tax litigation
We have been involved in many relevant litigation proceedings assisting domestic and foreign clients before tax courts of all types and levels, including the Court of Cassation and the European Court of Justice. The ability to tackle criminal implications possibly arising from tax assessments is another strength of our tax team. Particular experience has been gained with respect to disputes related to permanent establishments and transfer pricing. In connection with the latter, we have filed proceedings before the competent authorities and under the European Arbitration Convention. In addition, we have relevant expertise in assisting clients during tax audits and in the management of dispute-resolution procedures.
