Tax and Legal
Associated Firm

We provide tax advisory services and operational support in managing recurring tax obligations, assisting businesses and corporate groups in coordinating and properly executing their activities. Advisory on ordinary tax matters and interpretation of tax regulationsPreparation and filing of tax returns (Corporate Income Tax – IRES, Regional Tax – IRAP, VAT, Form 770, Withholding Tax Certificates – CU), including local tax filings and paymentsTax oversight of accounting records and financial statements for reporting purposesSupport in interactions with the Italian Tax AuthoritiesSupport to corporate functionsMonitoring and management of historical tax positions Tax and accounting due diligence

We offer advisory services in managing tax issues that arise in the ordinary and extraordinary business operations of companies. Our advisory approach focuses on risk prevention and optimization of tax structures. Ordinary and extraordinary corporate taxationTax consolidation and fiscal transparency regimesTaxation under IAS/IFRS standardsTax planning in corporate reorganizationsTargeted Tax due diligenceDrafting of tax opinions and memorandaTax ruling

We assist clients in managing VAT and other indirect taxes. VAT treatment of ordinary and extraordinary transactionsVAT on international transactionsEstablishment and management of VAT groups and group VAT settlementsAdvice on registration tax, mortgage and cadastral taxes, inheritance and gift tax, and stamp dutyPlanning of IMU (municipal property tax), TARI (waste collection tax), and other local taxesTargeted Tax due diligenceDrafting of tax opinions and memorandaTax ruling

We provide our expertise to companies already participating in the Cooperative Compliance regime, as well as to those preparing to enter it. Assessment of eligibility requirements for access to the Cooperative Compliance regimeDesign, implementation, and updating of the Tax Control Framework (TCF)Tax risk mapping and definition of control measuresPreparation of the documentation required for admission to, or maintenance of, the regimeManagement of relations with the Italian Revenue Agency within the framework of preventive and cooperative dialogueOutsourced Tax Risk Officer (TRO) servicesTax Control Framework certification and assurance servicesRisk disclosure communicationsFast-track advance tax rulings (abbreviated rulings)

We support companies and multinational groups in cross-border transactions, the management of double taxation risks, and the development of transfer pricing policies. Application of double taxation treaties and compliance with European tax legislationTax residence and permanent establishment mattersPreparation of Master File and Local File documentationEconomic benchmarking studies and functional analysesAssistance with Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs)Tax audits and tax litigationInternational tax rulings and planning of cross-border reorganizations

We provide assistance on customs duties, tariff classification of goods, and compliance requirements related to international import and export operations. Customs classification of goods and determination of applicable customs dutiesDetermination of preferential origin and support in obtaining and maintaining Authorized Economic Operator (AEO) statusImport and export customs declarationsCustoms audits and dealings with customs authoritiesTechnical and tax assistance in customs reassessment and adjustment proceedingsAdvice on the application of the Union Customs Code (UCC) and related EU customs legislation

We assist companies and energy sector operators in managing excise duties on electricity and energy products (including natural gas, petroleum products, and mineral oils), with particular focus on exemptions, tax reliefs, and duty suspension arrangements provided under Italian and European legislation. Excise warehousesExcise compliance and reporting obligationsExcise duty disputes and proceedings involving the Italian Customs and Monopolies AgencyTax Litigation and Alternative Dispute Resolution

We advise companies, shareholders, and business operators on the tax implications of corporate transactions, commercial agreements, and governance structures, both in the ordinary course of business and in extraordinary transactions. Tax analysis of corporate and contractual arrangementsTax aspects of mergers, demergers, and contributions in kindTax due diligenceTaxation of trusts and corporate control structuresTax treatment of shareholders’ agreements and corporate bylaws provisions

We support entrepreneurs and corporate bodies in managing situations of economic and financial imbalance, from the timely detection of warning signs of crisis to the selection of the most appropriate tool. We assist clients in drafting the recovery plan, in negotiations with creditors, and in dealings with the bodies of the procedure, where appointed, favoring solutions that allow for business continuity and the preservation of the company's value. Negotiated settlement of the crisisCertified recovery plansDebt restructuring agreementsComposition with creditors (concordato preventivo)Procedures for the composition of over-indebtedness crisesJudicial liquidation and controlled liquidation The firm also handles: Tax settlement We assist companies and professionals in settling tax and social security debts through tax settlement (transazione fiscale). We handle the assessment of the requirements, the preparation of the proposal to the tax authorities, and its coordination with the chosen crisis regulation tool, following the discussions through to court approval (omologazione), with the aim of reducing debt exposure and restoring the company's financial balance. Certifications The firm's professionals possess the professionalism and independence requirements set out by the Code of Business Crisis and Insolvency (Codice della crisi) and take on certifier (attestatore) roles within the framework of crisis regulation tools. This activity includes verifying the accuracy of company data and issuing an opinion on the feasibility of the plan, in addition to the special certifications required during the course of the procedure. We also prepare certifications relevant to tax and social security settlements, both within crisis regulation tools and in the context of negotiated settlement, with particular attention to assessing the advantageousness of the treatment proposed to public creditors compared to the liquidation alternative.

We provide tax assistance in the management of wealth, income, and asset transfers, including in an international context. Our services are integrated into sophisticated wealth management strategies. Personal income tax returns and tax compliance servicesWealth, estate, and succession tax planningSpecial tax regimes for new residents, inbound workers, and foreign pensionersTax and regulatory advice on luxury assetsTrusts, insurance policies, and other asset protection and wealth structuring toolsTax residence planning and international mobility matters