Areas of Practice:
INTERNATIONAL TAX PLANNING
Although often overused as a term, International Tax Planning as a tool to efficiently protect family-owned multinational companies and HNWI's international assets has a great importance in the modern economical scenario.
We specialize in the creation of corporate frameworks for the correct income allocation among the different countries where portfolio and industrial investments take place to take advantage of the favorable tax provisions adopted by countries engaged in the "virtuous tax competition" - including and especially Italy. We can help you employ the most suitable contractual instruments and legal entities to efficiently navigate the norms on permanent establishments, individuals and legal entities' residence, transfer price, double taxation avoidance, cross-border investments' income taxation and controlled foreign companies.
It might be most famous for its natural and cultural beauties, but Italy also offers a particularly favorable tax regime to individuals with foreign-sourced income and their families. We can help you transfer your tax residency and craft the most effective fiscal plan for your needs.
We also assist non-residents clients with taxable income in Italy with tax compliance and tax return preparation.
With art growing as an ever more important asset class, correctly handling its fiscality has become paramount for all collectors, owners and dealers. We have an extensive experience assisting national and international art galleries, artists, private collectors and non profit entities proprietors of art collections on a) cross-border movements and correlated VAT operations, b) estate planning for art collections, and c) art law and cultural assets management, authorization to export and resale rights.
Tax audits and the following phases of litigation may not only take a toll on managerial resources, but can potentially last for extended periods of time. We assist and guide our clients throughout the whole process, thanks to an extensive experience of successful litigations and extra-judicial settlements with tax authorities.
We also assist non-resident companies in the correct calculation of their taxable income produced in Italy, in accordance with mutual agreement procedures (MAP) and the International Treaties against double taxation.
ESTATE PLANNING AND FAMILY ASSETS REORGANIZATION
From civil partnerships to the most complex corporation, the use of the most appropriate juridical means is a key factor of estate planning. We have an extensive experience in the reorganization of family assets, including all the legal structures available in internal and international Law.
In cross-border situations, we carefully build the most suitable structure for family assets with roots in different countries. For every EP structure that we set-up, our goal is to maximise the ratio between the results obtained and the costs incurred in its creation.
We also offer a pioneering experience in family offices for multiple clients, paired with a controlling participation in an Italian trust company, the Fiduciaria Cavour (www.fiduciariacavour.it).
vat and customs
The world economy has never been more connected, but cross-border investments still require careful VAT planning. We can help you navigate this thanks to our extensive and constantly updated knowledge of European VAT norms and the sentences of the European Court of Law.
We assist both local and international companies on customs procedures and can also act as VAT representative for foreign companies with and without a permanent establishment in Italy.
MERGER AND ACQUISITIONS
With a far-reaching experience helping family-owned companies looking to grow by acquisition or planning an intergenerational transfer, as well as with the sale of established companies either to investors or to competitors, we can offer complete assistance during the M&A process. From the execution of tax, accounting and corporate due diligence, to the planning of extraordinary operations before the sale, in addition to negotiating and contractual assistance, we can help both for domestic transactions and for cross-border investments.
Whenever possible, we cooperate with the clients’ own legal counsel, or we can suggest one according to the value and complexity of the transaction.
ENTERPRISE VALUE APPRAISALS and business planS
A well-crafted company evaluation is central to any successful M&A negotiation or extraordinary corporate transaction. That’s where we come in: proficient in all current evaluation methods, we have decades of experience in company evaluations, the preparation of information memoranda, and reorganization plans, including the plans prepared in connection with pre-bankruptcy procedures and debt restructuring. We can also help with business plans, budgeting and reporting procedures.
Financial statements, accounting principles and corporate taxation
With a broad portfolio of clients across several sectors - from industrial, to manufacturing to services and property companies - we can assist clients in preparing Financial Statements in accordance to IFRS principles, both as an ordinary procedure and following any extraordinary corporate transactions.
Activities commonly performed include tax compliance connected to the Financial Statements, the determination of taxable income and other issues of income tax planning within the Italian corporate taxation system. We can also assist corporations, partnerships and all tax-subjects in Italy in their income tax return preparation.