Advice on tax, European and international law

Italian Tax and Corporate Consulting

  • Assistance on corporate and tax issues
  • Establishment of companies and partnerships and in-depth analysis of statutory and fiscal effects
  • Tax due diligence
  • Tax disputes and litigations

International Taxation

  • Assistance with the application of double taxation agreements (“DTAs) for all income and capital categories;
  • Assistance with preparation of specific requests to tax administrations for rulings on the application of specific national tax provisions, or of DTAs;
  • Assistance in the request for the activation of Mutual Agreement Procedures (MAPs) between tax administrations (e.g. MAPs between the Italian Inland Revenue Agency and the Italian Revenue Agency)

  • Preparation of suitable documentation to demonstrate the fairness (based on the “arm’s length price” principle) of the prices applied in intercompany transactions (transfer pricing);
  • Assistance in filing applications for Advance Pricing Agreements (APAs) on intra-group transfer pricing

SMEs interested in the internationalization in other EU countries through the creation of agencies, branches or subsidiaries, and large companies already present with their own offices in other European and non-European countries (using the company vehicles made available from their respective legal systems), need to consider their operating decision in the light of EU Court of Justice case law, EU legislation on direct and indirect taxes (as adopted in the Member States), international double taxation agreements entered into by the Member States with other EU countries and with third countries, OECD transfer pricing guidelines – as implemented in domestic legislation and in the operations of individual tax administrations – and the developments regarding OECD action against Base Erosion and Profit Shifting (BEPS).

  • Assistance for individuals moving abroad – or returning from abroad – for professional reasons, with regard to tax and social security implications (including pension-related issues)
  • International tax planning, including capital transfers, any bonuses and tax breaks related to international mobility

Commercial and Corporate Contracts

  • Drafting of opinions on specific issues of Italian company law and EU company law
  • Planning and management of generational transitions

  • Assistance in the negotiation and drafting of commercial contracts (also in English/French) with foreign counterparties, in the light of the respective national legislation of reference, the UNCITRAL / UNIDROIT Principles and the definitions developed by the International Chamber of Commerce;
  • Assistance in the negotiation and drafting of transport contracts, employment contracts, agency contracts, license contracts for the use of industrial property protection tools (patents, trademarks) and contracts of joint ventures;
  • Contractual consultancy: assistance aimed at highlighting in advance the legal implications, validity and effectiveness of commercial and business initiatives (drafting of ad hoc opinions on specific legal issues, preparation of compatibility opinions).

Contact

Headquarters in Jesi

Headquarters in Ancona – Associated Studio (Smart)