Tax advisory to corporates and individuals (namely HNWI) is one of the main area of advisory. Our advisory encompasses direct (i.e. tax on income) and indirect (i.e. VAT, registration/stamp duty tax, Financial transaction tax, etc), both domestic and cross-border (international tax planning):
Main area of tax advisory:
- Corporate taxation: it covers the taxation of business income at corporate and shareholder’s level, in the ordinary course of business as well as in the context of extraordinary transactions such as mergers & acquisitions, spin-offs, winding up, business combinations, transactions on debt and equity instruments (issuance of equities or participating financial instruments, bonds, bonds-assimilated, hybrids, etc.), tax optimization strategies (fully compliant with domestic and international regulatory frame (e.g. tax consolidation regime, CFC strategies, tax treaty optimization strategies, tax rulings);
- Financial products and wealth planning: tax treatment (for issuers and holders) of financial products (equities, bonds, investment funds, derivatives, hybrids, life insurance policies, currencies, precious metals), trusts, real estates, as well as portfolio management strategies (dedicated wrappers). Strictly related to this area is tax advisory in the field of wealth and succession planning;
- International taxation: main area of advisory concerns application of tax treaties, procedures for exchange of tax information and related compliance duties for financial operators CRS, DAC6 EU Directive, etc.) , anti-abusive provisions (CFC rules, black listed companies regimes, off-shore opaque structures), tax planning of investments and acquisition in Italy by foreign operators, etc.;
- Taxation in the area of insolvencies and restructuring
