The globalization of markets has made it inevitable to deal with international tax issues. Our specific consultancy on global tax matters includes innovative high value-added proposals for both large multinational groups and “pocket-sized” multinationals regarding cross-border activities and transactions, as well as potential conflicts of domestic tax laws in different jurisdictions.

• We handle cross-border mergers and acquisitions, IP companies and licensing agreements, planning and implementation of reorganization transactions for Italian groups with presence abroad or foreign groups with presence in Italy, tax aspects of extraordinary finance operations, LBOs, securitization, acquisition finance and structured finance. We identify the most tax-efficient structure for cross-border acquisition transactions, both inbound and outbound, prepare requests for rulings to disapply specific regulations (Controlled Foreign Companies, dividends from blacklisted sources, capital gains related to foreign shareholdings), apply and interpret International Double Taxation Conventions, apply Arbitration Conventions, assist in International Ruling procedures, examine issues of EU tax law and apply EU Directives on dividends, interest and royalties.
• In transfer pricing matters, we provide assistance including analysis and planning of group policies, preparation of inter-company agreements and documentation relating to transactions in accordance with applicable regulations. We have solid experience in the presentation of international rulings.
• We support our clients in VAT compliance matters and refunds to non-residents, tax and VAT representations, as well as high net worth individuals and tax expatriates, assistance in tax audits and in the pre-litigation and litigation phases following assessments.