Corporate and group taxation
Advice on corporate tax and group tax issues, including matters specific to IAS/IFRS adopters and banking, financial and insurance institutions. Assistance on special tax regimes, including those relating to intellectual property and cooperative compliance programs.
M&A and business restructuring
Advice on the tax ramifications of domestic and cross-border group reorganizations, LBOs and MBOs, transfer of intellectual property and company migrations. Assistance in determining the optimum structure for international transactions. Tax due-diligence, negotiations and drafting of contract terms on tax matters as well as dealing with tax authorities in obtaining tax rulings.
Transfer pricing
Advice to multi-national enterprises on the selection of the transfer pricing methodology, the drafting of transfer pricing documentation and the negotiation of advance pricing agreements with the relevant tax authorities, both in Italy and abroad. Assistance on tax optimization of supply chain models. Assistance on litigation and mutual agreement procedures for the elimination of international double taxation.
International and EU tax law
Advice on tax issues concerning international and EU law, particularly with regard to the application the double tax treaties, cross-border restructuring and income flows and OCSE Action Plan on BEPS. Assistance on the application of European tax Directives. Assistance before the European Court of Justice and the European Court of Human Rights.
Taxation of financial instruments and financial transactions
Advice on the tax ramifications of equity and capital market, structured finance, financing and securitization transactions. Assistance to financial institutions and investment funds on the tax treatment of investments, asset management services and financial instruments.
Taxation of real estate
Advice on the tax ramifications of residential and commercial real estate transactions and renewable energy businesses. Assistance to real estate funds and other institutional investors, as well as private and corporate clients, in structuring and reorganising real estate investments both in Italy and abroad.
Tax litigation
Legal assistance and advice to taxpayers in refund procedures, tax audits and investigations including extrajudicial tax disputes resolution. Legal assistance and expert advice on tax and penal matters including tax litigation procedures before tax authorities, provincial and regional tax courts, higher courts (i.e. Court of Cassation, Council of State, Constitutional Court) and international courts (i.e. European Court of Justice, European Court of Human Rights).
High net wealth individuals, trusts and foundations
Advice to high net wealth individuals on estate and succession planning, transfer of businesses, lifetime transfers, asset governance. Assistance to trusts and foundations as well as to charities and other non-profit entities.
Taxation of individuals
Advice on transfers of tax residence from or to Italy. Assistance on the tax ramifications of the acquisition of residential property and other investments in Italy and abroad, including art work, aircraft and vessels.
Stock options and incentive plans
Advice on the taxation of compensation packages for executives, including variable remuneration, fringe benefits and welfare benefits. Assistance on the taxation of expatriates, including the tax implications of incentive plans, stock based compensation, carried interest and co-investment structures.
VAT, customs and excise duties
Advice on VAT issues in relation to both domestic and cross-border transactions, including real estate, financial transactions and supply chain restructuring. Assistance in dealing with customs and excise duties and transfer pricing.