Drafting of advices on tax aspects of national and international operations.
Tax planning and support of the procedures of spreading abroad, such as: establishments of companies, holdings, controlled companies, braches, representative offices, etc…
Examination of the tax aspects linked to national, international, across the border, EU or extra EU levels extraordinary operations (merging, breakaway, contributions of company, exchange of stocks, etc) and arrangement of strategies for optimizing multinational groups taxation systems.
Closer examination of risks and tax problems linked to the operativeness on international markets, in the light of EU, agreed and internal dispositions and, more precisely:
analysis of the existence of the necessary conditions for the assignation of a residence for tax purposes in Italy and abroad and, in case of relocation of this last abroad, assessment of the “Exit Tax” effects;
relocation abroad check up;
spotting and examination of the elements that represent the Material and Personal Permanent Establishment in Italy and abroad;
“Hidden” Permanent Establishment Check up;
verification of Black List and White List CFC (Controlled Foreign Companies) regime enforceability;
effectiveness assessment of the discipline on Black List Costs non-deductibility;
strategies planning and documents arrangement regarding Transfer Prices of mid-group operations with subsidiary companies (Transfer Pricing).
Formulation and filing of the different kinds of interrogations before the financial Administration:
Arrangement and improvement of international Ruling Agreements alongside the financial Administration with regard to the regulations concerning:
Prevention of the possibilities of Evasion, Avoidance, and Abuse of Process.
Verification and planning of the advantages coming from Double Tax Treaties and activation of mutual agreement procedures for the settlement of disputes regarding their correct enforcement and interpretation.
Assessment of the implications due to Exchange of Information, Tax Transparency and Administrative Cooperation among financial Administration of States, provided for by the Conventions against double taxation and Multilateral and Bilateral Agreements.
Analysis and closer examination of VAT, intra-EU and extra-EU aspects, besides those related to other indirect taxes.