Recent assignments

Our firm, which specialises in all the main areas of domestic and international tax law, offers its clients assistance both in and out of court.

Clientele

The Giordano Merolle Tax Law Firm provides personalized assistance aimed at resolving complex legal and tax issues, often of an innovative nature, for the benefit of a national and international clientele consisting of:
  • banks
  • financial intermediaries
  • insurance companies
  • asset management company
  • mutual funds
  • SICAVs and SICAFs
  • private equity firms
  • industrial companies
  • trusts
  • family office
  • trust company
  • banking foundations
  • welfare institutions
  • pension funds
  • private universities
  • public bodies
  • trade associations
  • workers' unions
  • third sector entities
  • high net worth individuals

Sectors

The Giordano Merolle Tax Law Firm provides consulting, assistance, representation and trial defense for companies and entities operating in various target industries and business sectors:
  • banking
  • financial
  • insurance
  • real estate
  • welfare
  • energy
  • healthcare
  • industrial
  • computer scientist
  • communications
  • pharmaceutical
  • transportation
  • distribution
  • fashion
  • art
  • show
  • publishing
  • education
  • philanthropy

Litigation

The Giordano Merolle Tax Law Firm has successfully represented its clients in numerous court cases. Thanks to our in-depth knowledge of the law and our long experience in the field, we are able to provide targeted and personalized defense for our clients in often highly complex litigation.

Recent assignments include representation and defense:
  • for a multinational group operating in the energy sector in relation to numerous disputes concerning the occupation of public land
  • for a foreign bank during a tax audit aimed at ascertaining the existence of a hidden permanent establishment
  • for an Italian bank in proceedings concerning the classification for indirect tax purposes of an unauthenticated private agreement acknowledging a debt
  • for an Italian company in proceedings before the Court of Cassation concerning allegedly evasive transactions
  • for renewable energy producers in judgments concerning the reimbursement of extraordinary contributions on extra profits
  • for companies and real estate funds in lawsuits concerning cadastral income and local taxes
  • for general contractors and financial intermediaries in tax audits and tax proceedings concerning the entitlement to building bonuses
  • for various Italian companies in proceedings concerning alleged VAT carousel fraud
  • for an Italian holding company in proceedings for the reimbursement of IRES (corporate income tax) unduly paid in Italy following its liquidation in favor of foreign shareholders
  • for an Italian holding company in proceedings concerning the VAT classification of an intra-group cash pooling agreement
  • for a foreign SICAF in the lawsuit for the reimbursement of income taxes relating to property rentals and indirect taxes paid at the time of transfer
  • for numerous SMEs in tax audits and judgments on the eligibility for tax relief relating to research and development activities
  • for numerous individuals in proceedings concerning claims for reimbursement for double taxation on foreign dividends
  • for trust in judgments concerning tax interposition and gift and inheritance taxes.

Consulting

The Giordano Merolle Tax Law Firm has provided out-of-court advice to numerous companies, groups of companies, mutual funds, resident and non-resident individuals, and professionals, offering customized and targeted solutions in the domestic and international spheres.

Recent assignments include assistance with:
  • to a SICAV and a SICAF held by a pension fund in the implementation of a tax-neutral merger
  • to an asset management company in the award of the tender for the management of Italian hetero-managed SICAVs and SICAFs launched by a pension fund
  • to a private university in the process of transforming it into a limited liability company
  • to a pension fund in the establishment of a real estate asset management vehicle
  • to a pension fund in structuring a vehicle for managing its movable assets
  • to a multinational group in the reorganization of its permanent establishments and subsidiaries based in Italy
  • to an Italian bank on tax issues relating to the securitization of consumer loans
  • to numerous non-resident taxpayers in submitting requests for rulings in order to benefit from preferential tax regimes for transferring residence to Italy
  • to a research consortium in the submission of a request for a ruling regarding its classification as a taxpayer subject to IRES and IRAP
  • to numerous individuals, both residents and non-residents, in resolving legal and tax issues relating to inheritance and asset planning
  • to a multinational company in a friendly settlement procedure concerning a dispute between Italy and France
  • an Italian industrial company in preparing a request for a ruling on the non-application of limits on the carryforward of losses following a demerger
  • to numerous resident and non-resident companies and holding companies in various extraordinary transactions, such as acquisitions of shareholdings, contributions, mergers, and demergers
  • to numerous taxpayers in the management and tax planning of generational transitions and in the establishment of trusts
  • a group of companies in the reorganization of their shareholdings through the transfer to a family holding company .
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Comments

Our comments on the official practices of the Revenue Agency and on tax law rulings. For continuous updates on the latest developments in the tax sector.
March 10, 2026

Revenue Agency, response to request for ruling no. 51 of February 25, 2026

The Italian Revenue Agency has clarified that the establishment of surface rights on agricultural land owned by a natural person...
March 10, 2026

Italian Revenue Agency - Resolution no. 8/E of February 23, 2026

The Italian Revenue Agency has provided clarification regarding the extension of tax relief schemes linked to repatriation...
March 10, 2026

Court of Cassation, order no. 3664 of February 18, 2026

The Supreme Court has ruled that, with regard to the collection of taxes whose taxable basis has been realized...