Taxation

The firm is involved in all areas of tax law, including the following:

Tax planning

  • corporate tax planning projects involving domestic or international issues for listed and unlisted companies;
  • extraordinary operations in connection with reorganizations and negotiation with third parties for the acquisition or sale of businesses or participations in companies;
  • planning and advice on the complex issues concerning the tax effects of corporate restructuring projects, such as the extraordinary administration of large companies in default;
  • the firm has been thoroughly involved in the first and leading case in Italy;
  • income and transfer tax implications of project financing transactions;
  • transfer pricing: analysis, review and management of TP procedures, including the drafting of comparability analysis, master files and country files.

Tax Office procedures and litigation

  • assistance during the course of extended audits by the Tax Agent for taxes on income, VAT, and other levies;
  • client’s representation for self-remedy procedures, including settlements with the Tax Agent;
  • ruling procedures, MAP and APA;
  • planning and implementation of defense strategies for tax controversy and representation in litigation, pleading, at various levels, up to the Italian Supreme Courts (Cassazione and Corte Costituzionale).

Opinions rendered

  • vast number of opinions on the interpretation of specific provisions of tax legislation and regulations, as applied to each client's circumstances;
  • the issues dealt with involve corporate taxation (income taxes, domestic and intraeuropean, IVA, custom duties, local taxes, etc., including tax collection, withholding taxes, foreign tax credits, etc...);
  • taxation of employee wages and fringe benefits, such as stock options, insurance policies, profit sharing plans, personal use of company car, etc...

Assistance

  • assistance in the preparation of financial statements and tax returns, in support, as needed, to the internal resources of each client;
  • design and implementation of procedures aimed at investigating the adequate compliance with tax laws and regulations on specific areas, such as promotional operations, expenses for conferences and sponsorships, management of professional relationships, fringe benefits, transfer pricing, etc...

Due diligence

  • performance of due diligence engagements focused on the tax and contractual posture in case of acquisitions, sales, mergers or other corporate reorganizations.

Judicial proceedings

  • expert representative of one of the parties, in Italian civil or criminal judicial proceedings;
  • participation as expert witness in US judicial proceedings.