Sectors
The team of professionals at Studio Legale Tributario Giordano Merolle provides tax legal advice, assistance in m&a, private equity, real estate, wealth planning and restructuring transactions, as well as representation in judgments of merit and legitimacy concerning these matters.
tax law
- Legal opinions on direct, indirect, property, excise, relief, abuse of law, state aid, and local taxes
- Out-of-court advice and pro-veritate opinions on international taxation, direct taxes, indirect taxes, and wealth taxes, with special focus on corporate and personal income taxes, VAT, excise taxes, tax breaks, extraordinary and corporate reorganization transactions including cross-border transactions, and abuse of law, ensuring clients' tax risk reduction.
- Assistance in tax audits, in the stages following the delivery of the tax audit report and in the out-of-court settlement of the tax claim
- We also provide advice in relation to state aid and European and international tax regulations, international tax planning, interpretation and application of double tax treaties as well as relevant European directives, ensuring compliance with the law and tax obligations of the solutions adopted by our clients.
- Tax litigation in Tax Courts, Supreme Court, and other higher jurisdictions
- We represent clients in complex litigation before the Tax Court, Court of Cassation, Constitutional Court, and in international cases before the Court of Justice of the European Union and the European Court of Human Rights. Our experience ensures strategic and focused defense at every stage of the process.
- Technical advice in criminal proceedings for tax, economic and bankruptcy offenses
- We offer technical advice in criminal proceedings related to tax, economic and bankruptcy offenses. In particular, we provide our assistance by verifying the configurability of the crimes in the hands of our clients from a substantive standpoint and working in synergy with professionals experienced in criminal matters in identifying the best defensive strategies, coordinating the needs of the criminal process with the tax process.
- Assistance in the filing of petitions of interpellation with the Internal Revenue Service
- We provide advice in the preparation and submission of ordinary, evidentiary, disapplicative, and anti-abuse interpellation petitions, with the aim of obtaining official clarifications from tax authorities and reducing legal uncertainty about future tax decisions. We also offer assistance to companies intending to make investments in the territory of the State of an amount of not less than 15 million euros and with "significant" and "lasting" employment effects in relation to the activity in which the investment takes place in preparing and filing interpellations on new investments.
- Assistance in friendly procedures and international arbitration
- The firm provides expert assistance in international tax dispute resolution MAPs, such as conventional MAPs, arbitration MAPs, bilateral APAs, mutual agreement procedures under Legislative Decree 49/2020. We support clients in finding consensual solutions to disputes that may arise in tax matters, including through mechanisms provided for in international conventions, and represent clients in international arbitration proceedings.
- Assistance in judgments concerning state or local government property revenues
- The firm provides specialized legal assistance in legal proceedings related to state or local government property revenues. This activity includes the protection of clients in disputes concerning taxes, fees, concessions, and other property revenues, with specific reference to local government revenues such as COSAP (Fee for the Occupation of Public Spaces and Areas) and CUP (Single Property Fee). We offer comprehensive support in the management of litigation, from the analysis of the claims of the financial administration to representation before the competent judicial and administrative authorities.
- Legal Opinions on Direct, Indirect, Property, Excise, Facilities, Abuse of Law, State Aid and Local Taxes
We provide pro-veritate opinions on direct, indirect and property taxes, with a particular focus on IRES, IRPEF, VAT, excise, tax facilities, extraordinary and corporate reorganization transactions including cross-border transactions and abuse of tax law. We also advise in relation to state aid and European and international tax regulations, interpretation and application of double taxation treaties as well as relevant European directives, ensuring compliance with the law of the conduct adopted by our clients. We also advise on local government taxes and property revenues. - Assistance in tax audits, post-delivery stages of the tax audit report and out-of-court settlement of the tax claim
We provide support in tax audits conducted by the Internal Revenue Service and the Guardia di Finanza, including out-of-court settlement of the tax claim. We assist our clients in tax audits with adherence to the tax audit report or tax amends. - Tax litigation in Tax Courts, Supreme Court and other higher jurisdictions
We represent clients in complex litigation before the Tax Court, Court of Cassation, Constitutional Court and in international cases before the Court of Justice of the European Union and the European Court of Human Rights. Our experience ensures strategic and focused defense at every stage of the process - Technical advice in criminal proceedings related to tax, economic and bankruptcy offenses
We offer technical advice in criminal proceedings related to tax, economic and bankruptcy offenses. In particular, we provide our assistance by verifying the configurability of the offenses in the hands of our clients under the profile of merit and working in synergy with professionals experienced in criminal matters in identifying the best defensive strategies, coordinating the needs of the criminal process with the tax process. - Assistance in the submission of interpellation petitions to the Internal Revenue Service
We provide advice in the preparation and submission of ordinary, evidentiary, disapplicative, and anti-abuse interpellation petitions, with the aim of obtaining official clarifications from the tax authorities and reducing legal uncertainty about future tax decisions. We also offer assistance to companies intending to make investments in the territory of the State of an amount of not less than 15 million euros and with "significant" and "lasting" employment effects in relation to the activity in which the investment takes place in preparing and filing interpellations on new investments. - Assistance in mutual agreement procedures and international arbitration
The Firm provides qualified assistance in international mutual agreement procedures for the resolution of tax disputes, such as conventional MAPs, arbitral MAPs, bilateral APAs, mutual agreement procedures under Legislative Decree 49/2020. We support clients in finding consensual solutions to disputes that may arise in tax matters, including through mechanisms provided for in international conventions, and represent clients in international arbitration proceedings. - Assistance in litigation related to state or local government property revenues
The firm provides specialized legal assistance in litigation related to state or local government property revenues. This activity includes the protection of clients in disputes concerning taxes, fees, concessions and other property revenues, with specific reference to local government revenues such as COSAP (Fee for the Occupation of Public Spaces and Areas) and CUP (Single Property Fee). We offer comprehensive support in the management of litigation, from the analysis of the claims of the financial administration to representation before the competent judicial and administrative authorities.
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m&a, private equity and real estate
- Extraordinary and Corporate Reorganization Transactions
We provide advice and assistance in extraordinary transactions, such as mergers, acquisitions, and corporate reorganizations. We support clients throughout the entire process, from the preliminary assessment, through tax and legal due diligence, to the structuring and negotiation of transactions, ensuring that objectives, including tax optimization, are achieved in full compliance with applicable regulations. - Transfers of shareholdings and companies
We provide comprehensive legal and tax assistance in transactions involving the transfer of corporate shareholdings and companies, accompanying clients at every stage of the process. In particular, we support in the preliminary assessment of transactions, providing strategic analysis and identifying the main risks and opportunities of each type of transaction. We handle tax and legal due diligence, examining the regulatory compliance and tax implications of the transaction. In addition, we assist in the negotiation and drafting of contractual terms, ensuring the protection of the client's interests and full compliance with applicable regulations. - Real estate investment transactions, real estate management and development
We provide comprehensive legal and tax assistance in transactions involving the transfer of corporate interests and companies, accompanying clients at every stage of the process. In particular, we support in the preliminary assessment of transactions, providing strategic analysis and identifying the main risks and opportunities of each type of transaction. We handle tax and legal due diligence, examining the regulatory compliance and tax implications of the transaction. In addition, we assist in the negotiation and drafting of contractual terms, ensuring the protection of the client's interests and full compliance with applicable regulations. - Establishment of corporate vehicles and mutual funds
We provide assistance in the establishment and structuring of corporate vehicles asset management companies (SGRs), mutual funds, collective investment schemes (CIUs) and other corporate vehicles intended for financial or real estate transactions. We ensure that the establishment and governance of such funds comply with industry regulations and are optimized to attract investors, improve return on investment, optimize tax efficiency, and ensure compliance with regulatory standards. - Financing Transactions, Credit Securitization and Structured Finance
We provide highly specialized assistance in financing transactions, credit securitization and structured finance, with a specific focus on the tax aspects associated with such transactions. We assist companies in raising capital through loans, bond issues and debt instruments, ensuring optimal tax planning and full compliance with tax as well as financial and regulatory regulations. In receivables securitization transactions, we support clients in structuring the transaction, analyzing the tax implications related to the transfer of receivables, the management of special purpose vehicles (SPVs) and the tax treatment of cash flows. In structured finance, the firm provides assistance in the design and implementation of complex instruments, such as derivatives, project finance transactions and leveraged finance. - Acquisition of Assets and Companies through Turnaround Transactions
We provide legal advice in the acquisition transactions of distressed assets and companies, facilitating the restructuring and "turnaround" of distressed companies. We work to optimize acquisition processes, including recovery plans and legal strategies to ensure successful corporate restructuring.
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wealth planning
- Generational Transition of Family Businesses
We advise on the generational transition of family businesses, creating plans to ensure the continuity of the business through successive generations. Our advice includes structuring holding companies, tax planning, and establishing agreements among family members to prevent conflicts and optimize asset management... - Structuring Corporate Holding Companies
We help corporations and listed companies structure corporate holding companies, optimizing the management and protection of corporate assets. We provide support in parent company formation, holding company management, and tax planning, creating a structure that promotes growth and protects strategic assets. - Establishment of trusts and private foundations
We provide legal advice in the establishment of trusts and private foundations for asset protection and estate planning. We ensure that the structure chosen meets the client's objectives, protecting assets and optimizing the tax burden of the transaction. - Asset Protection
We provide customized asset protection and tax optimization advice, assisting individuals, entrepreneurs and businesses in safeguarding and strategically managing family and corporate assets. We support clients in wealth planning through the use of advanced legal and tax tools, such as trusts, holding companies, foundations, and other corporate or contractual vehicles. - Estate Planning and Inheritance Divisions
We help clients plan the succession of their assets through legal and tax strategies for dividing inheritances. We work on customized solutions that reduce fiscal impact and minimize conflicts among heirs, ensuring a smooth transition of wealth and family affairs. - Establishment of third sector entities
We advise on the establishment of third sector entities, foundations and associations, supporting clients in the fiscal planning and structural organization of the entity. We help optimize the management and fiscal sustainability of these entities, ensuring compliance with regulations and respect for social and solidarity purposes.
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restructuring
- Preparation and Attestation of Business Recovery Plans
We support distressed companies in preparing and attesting to business recovery plans, helping them devise recovery strategies and manage creditors. Our advice includes analyzing the financial situation, creating restructuring plans and negotiating with the parties involved. - Management of negotiated business crisis settlement procedure
We assist in negotiated business crisis settlement procedures, facilitating mediation between debtors and creditors to find mutually beneficial solutions. We undertake agreement drafting and negotiation management to resolve the business crisis effectively. - Negotiation of agreements in execution of attested rehabilitation plans
We assist companies in negotiating and executing agreements related to attested rehabilitation plans, aimed at debt restructuring and restoring corporate solvency. We support clients in developing practical strategies for renegotiating liabilities and strengthening financial position. - Negotiation and probate of debt restructuring agreements
We advise on debt restructuring agreement negotiations, including proceedings for the probate of agreements. We help companies reach solutions to overcome the financial crisis, protecting the interests of all parties involved. - Representation in tax and contribution settlement procedures
We handle the legal representation of companies involved in tax and contribution settlement procedures aimed at reducing tax and contribution debts. Our assistance includes negotiation with tax authorities to obtain favorable solutions and compliance with tax obligations. - Assistance in appeals for composition with creditors and other minor procedures
We provide legal advice in appeals for composition with creditors, including proceedings for other minor bankruptcy procedures, such as debt restructuring agreements. We help companies draft the composition plan and negotiate terms with creditors to avoid bankruptcy.
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Contact us
If you would like more information, you can write to our secretary via the contact form.
