Services

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 regulations
• Preparation and filing of tax returns (Corporate Income Tax – IRES, Regional Tax – IRAP, VAT, Form 770, Withholding Tax Certificates – CU), including local tax filings and payments
• Tax oversight of accounting records and financial statements for reporting purposes
• Support in interactions with the Italian Tax Authorities
• Support to corporate functions
• Monitoring 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 taxation
• Tax consolidation and fiscal transparency regimes
• Taxation under IAS/IFRS standards
• Tax planning in corporate reorganizations
• Targeted Tax due diligence
• Drafting of tax opinions and memoranda
• Tax ruling

We assist clients in managing VAT and other indirect taxes.

• VAT treatment of ordinary and extraordinary transactions
• VAT on international transactions
• Establishment and management of VAT groups and group VAT settlements
• Advice on registration tax, mortgage and cadastral taxes, inheritance and gift tax, and stamp duty
• Planning of IMU (municipal property tax), TARI (waste collection tax), and other local taxes
• Targeted Tax due diligence
• Drafting of tax opinions and memoranda
• Tax 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 regime
• Design, implementation, and updating of the Tax Control Framework (TCF)
• Tax risk mapping and definition of control measures
• Preparation of the documentation required for admission to, or maintenance of, the regime
• Management of relations with the Italian Revenue Agency within the framework of preventive and cooperative dialogue
• Outsourced Tax Risk Officer (TRO) services
• Tax Control Framework certification and assurance services
• Risk disclosure communications
• Fast-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 legislation
• Tax residence and permanent establishment matters
• Preparation of Master File and Local File documentation
• Economic benchmarking studies and functional analyses
• Assistance with Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs)
• Tax audits and tax litigation
• International 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 duties
• Determination of preferential origin and support in obtaining and maintaining Authorized Economic Operator (AEO) status
• Import and export customs declarations
• Customs audits and dealings with customs authorities
• Technical and tax assistance in customs reassessment and adjustment proceedings
• Advice 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 warehouses
• Excise compliance and reporting obligations
• Excise 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 arrangements
• Tax aspects of mergers, demergers, and contributions in kind
• Tax due diligence
• Taxation of trusts and corporate control structures
• Tax 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 crisis
• Certified recovery plans
• Debt restructuring agreements
• Composition with creditors (concordato preventivo)
• Procedures for the composition of over-indebtedness crises
• Judicial 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 services
• Wealth, estate, and succession tax planning
• Special tax regimes for new residents, inbound workers, and foreign pensioners
• Tax and regulatory advice on luxury assets
• Trusts, insurance policies, and other asset protection and wealth structuring tools
• Tax residence planning and international mobility matters

We provide tax advisory services regarding financial instruments, incentive plans, and new forms of investment, with a focus on regulatory implications for individual investors, funds, and wealth managers. Our services integrate with wealth management strategies for the protection and optimization of crypto-assets.

• Tax classification of equity and debt instruments
• Taxation of dividends, interest, and capital gains
• Stock options, performance bonuses, and employee welfare plans
• Acquisition, holding, and disposal of crypto- assets and NFTs
• Regularization of past positions and anti-money laundering compliance
• Tax and accounting advisory for funds, wealth management vehicles, and holding companies

We assist clients throughout all stages of tax audits and assessment procedures, providing technical representation before the Tax Courts. We also advise on alternative dispute resolution mechanisms that enable taxpayers to settle disputes with the tax authorities in a more efficient and cost-effective manner.

• Representation in tax litigation at all levels of jurisdiction, including before the Supreme Court and the Courts of the European Union
• Assistance in tax audits, inspections, and assessment procedures
• Tax refund claims and related litigation
• Alternative dispute resolution procedures and settlement mechanisms with the tax authorities