International taxation

The increase in international trade and increasing globalization have brought significant changes in the market and in production activities, creating significant difficulties, especially with regard to the rules of international tax law.

In most cases, a company wanting to relocate or to open branches abroad faces barriers comprising regulations that are difficult to understand and complex bureaucratic obligations. The Firm, expert in issues related to the internationalization of companies, assists businesses together with the support of the broad network of professionals it belongs to.

The Firm assists companies in evaluating relocation procedures, internationalization or repatriation of corporate structures, providing consulting services and advice on international tax issues.

Assistance is given to Italian organizations and subsidiaries of foreign groups in starting their business with accounting services and consultancy services to the Corporate bodies.

The following services are provided:

• assistance in selecting the geographic location of new production and/or distribution plants and the legal form to be adopted;
• in-depth study of the civil and tax law of the foreign country;
• preparation of business planning and tax planning;
• contractual consultancy services, also with regard to joint ventures;
• preparation of budgeting and reporting models used to monitor the performance of production units in foreign countries;
• designing of models intended to optimize cash flows within multinational groups;
• support in the establishment of foreign holdings, trusts, and permanent establishments;
• collaboration in the implementation of extraordinary cross-border transactions;
• analysis and proper use of the opportunities provided by international conventions;
• assistance in the defence of tax assessments related to direct and indirect taxation concerning relations with foreign countries;
• CFC regimes (Controlled Foreign Companies);
• preparation of international ruling petitions.

The Firm specializes in the preparation of transfer pricing projects, which include the procedures and documentation (e.g., Master file and Country Specific) established by supranational authorities, current legislation, and/or internal procedures.

The Firm provides assistance on customs procedures, providing expert support during all phases of the relationship with foreign countries: imports, exports, litigation, contacts and relations with relevant authorities, operators, and foreign professionals.

The Firm can also assist and support the submission of the Authorised Economic Operator (AEO) application to the relevant customs authorities and subsequent procedures.

The Firm provides assistance under the Voluntary Disclosure procedure in order to report and regularize the possession of assets abroad.

With proven experience and specialization in the field, the Firm is an authorized intermediary for the transmission of the voluntary disclosure program application form, assisting the taxpayer in the presentation of the report and the necessary documentation. The activities performed by the Firm also include the initiation of adversarial proceedings with tax authorities.