Tax law

Legal opinions on direct, indirect, property, excise, relief, abuse of law, state aid, and local taxes

In the contemporary tax landscape, the correct interpretation of tax regulations is crucial to avoid legal risks and optimize the tax management of individuals, professionals and companies.

We offer pro-veritate opinions on a wide range of tax issues, including:

• Direct taxes (Irpef, Ires, etc.): advice on the interpretation and application of income taxes for individuals and corporations.
• Indirect taxes (VAT, transaction taxes, etc.): support in regulatory interpretation and tax planning strategies.
• Taxes (IMU, TASI, TARI, etc.) and Local Government Property Revenues (COSAP, CUP): fiscal analysis and optimization for property and financial asset management.
• Excise: assistance with indirect taxes on certain goods (alcohol, tobacco, energy, etc.), with a focus on sector-specific regulations.
• Tax breaks: advice on incentives and tax credits available to individuals and businesses, including grants for research and development, investments in start-ups, and more.
• Abuse of right and aggressive tax planning: opinions in relation to anti-abuse legislation and potentially risky tax strategies.
• European and international tax law: advice on transnational tax management and compliance with European and international regulations.
• State Aid: analysis and advice on the compatibility of tax breaks with state aid regulations, especially in an international context.

Our goal is to provide expert and confident guidance in tax matters, responding with customized and clear solutions to the client's needs.

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

Our assistance in tax audits and tax assessments extends to all stages of control by the Internal Revenue Service and the Guardia di Finanza. We offer professional support to deal calmly and efficiently with the following situations:

• Tax audits: assistance during the stages of access and verification by the Internal Revenue Service and the Guardia di Finanza and the issuance of audit reports or daily reports to be footnoted on statements.
• Assessment with adherence: assistance in the procedure of assessment with adherence to the report of findings with settlement of the objections raised by the assessing bodies with abatement of the penalties due and without having to resort to the judicial authorities, avoiding the long duration of litigation.
• Arbitrary repayment: assistance in the procedure of regularization of the objections raised by the assessment bodies by paying the taxes due and reduced penalties, plus interest.
• Out-of-court settlement of the tax claim: support in negotiations with the tax administration to resolve disputes before the tax act is challenged and thus without the need to institute a lengthy and time-consuming court case.

Each stage of these processes is handled with the utmost care and expertise, aiming to reduce risks and tax penalties by finding optimal solutions for the client.

Tax litigation in Tax Courts, Supreme Court, and other higher jurisdictions

In a complex tax system, disputes can sometimes reach higher levels, involving national and international courts of justice. We offer comprehensive tax litigation services in the following jurisdictions:

• Tax Court: defense and assistance during litigation in tax courts of first and second instance, with targeted strategies to achieve the best outcome.
• Supreme Court: support when appealing to the Supreme Court on tax issues, with an in-depth analysis of regulations and possible legal interpretations.
• Constitutional Court: advising on fiscal matters involving constitutional violations, ensuring that fundamental principles are respected.
• Court of Justice of the European Union: assistance in cases involving European tax law, to ensure the correct application of European directives and regulations.
• European Court of Human Rights: support for the defense of fundamental rights in relation to tax disputes that may violate the rights recognized by the European Convention on Human Rights.

With our experience in different courts and jurisdictions, we help our clients navigate through complex judgments with a strategic and results-oriented approach.