TAX ADVISORY

The Firm provides assistance and tax assistance to SMEs and major companies, including the drafting of tax declarations, assistance in accounting compliance (also through outsourced accounting) and managing digital invoicing and filing.

Our professionals assist companies in extraordinary operations (mergers, demergers, sales, conferrals, transformations and winding-up, operations on properties) and on matters relative to patent box and tax credits for investments, research and development, start ups and innovative SMEs, with a focus on the following activities:

Ordinary activities:

• assistance in activity of determining the current taxes (aka “tax fund”);
• assistance in drafting tax records, IRAP and VAT;
• answering specific queries on direct international and domestic tax (IRES and IRAP);
• answering specific queries on indirect taxes (VAT and duty);
• assistance on the analysis of the criteria for qualification, temporal imputation and classification required by the correct accounting principles to be applied to ordinary business, evaluating the effects in terms of the determination of the tax base;
• verifying the determination of current taxes (aka “second level control”);
• elaboration and analysis of the financial statements indices.

Extraordinary activities:

• assisting in planning and/or executing extraordinary operations (mergers, demergers, conferrals and winding-up), with the possibility to arrange expert evaluations on the target companies;
• assisting in accounting and tax matters on passing on to international IAS-IFRS accounting principles or, within the same accounting frame (IAS-IFRS principles or Italian accounting principles OIC), in adopting specific accounting principles (i.e. passing to IFRS 9);
• assisting in analysing the tax effects arising from the presence of financial instruments of “fair value” protection or cash flow;
• assisting in preparing ordinary, probative, disapplicative and anti-avoidance rulings;
• assisting in preparing “national documentation” required for Transfer Pricing (determining the normal value and assisting in the procedure of “international ruling”, use of alternative measures, drafting annexed documentation and coordinating economic analysis);
• drafting elaborates or opinions on tax regime of specific operations of ordinary or extraordinary nature, keeping in mind possible abuse of law;
• assisting in filing the request to access the so called “patent box” regime;
• assisting in determining the tax credit intended for research and development”;
• assisting in determining the so called “advertising bonus”;
• participating in “tax due diligence” operations required during sales and acquisitions of company shares, company parts or other extraordinary operations;
• assisting before the Italian Revenue Agency and other tax authorities with respect to notifications of assessments/payments;
• assisting in tax audits and administrative procedures with respect to tax litigation;
• defence in court in tax procedures and in Supreme Court;
• assistance in drafting requests of assessments and facilitated definition of tax burdens and non registered burdens for the period 1.1.2000 – 31.12.2017 (art. 3 Law no. 119/2018);
• assistance in drafting requests for facilitated definition of pending tax procedures (art. 6 Law no. 119/2018);
• assisting in finalizing preventive agreements ex art. 31-ter Law 600/1973 with the tax administrations.