Activities
Giordano Merolle's Studio Legale Tributario provides personalized assistance aimed at solving complex, often innovative legal and tax issues 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
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
Giordano Merolle Tax Law Firm has successfully represented its clients in numerous court cases, defending companies, groups of companies, investment funds, resident and nonresident individuals and professionals in all stages of legal and tax litigation.
With our in-depth knowledge of the regulations and long experience in the industry, we are able to provide targeted and customized defense for our clients.
The firm has assisted clients in tax disputes involving complex issues such as challenges of abuse of tax law, application and disapplication of withholding taxes for outbound income streams such as dividends, interest and royalties, CFC regulations, esterovestification, carousel fraud in the VAT area, recovery of concessional tax credits, and refunds of direct and indirect taxes paid unduly.
Recent assignments include assisting:
- for a foreign bank during a tax audit aimed at establishing the existence of a concealed permanent establishment.
- for an Italian bank in judgments concerning the qualification for indirect tax purposes of an unauthenticated private deed of acknowledgement of debt.
- for an Italian company in the Supreme Court case involving allegedly elusive transactions worth 100 million euros.
- for renewable energy producers in judgments of reimbursement of extraordinary contributions on extra-profits.
- for corporations and real estate funds in judgments on cadastral rent and local taxes.
- for general contractors and financial intermediaries in tax audits and tax judgments on the eligibility of construction bonuses.
- for various Italian companies in judgments involving alleged carousel fraud for VAT purposes.
- for an Italian holding company in litigation for the refund of IRES unduly paid in Italy following its liquidation in favor of foreign shareholders.
- for an Italian holding company in the judgment concerning the VAT qualification of an intra-group cash pooling arrangement.
- for a foreign SICAF in the lawsuit for the refund of income taxes pertaining to real estate leases and indirect taxes paid upon the transfer of said real estate.
- for Italian multinational companies in judgments for taxes and occupation fees on public spaces and areas, as well as from land encumbered by civic uses.
- for numerous SMEs in tax audits and judgments on the eligibility of tax benefits related to research and development activities.
- for numerous individuals in judgments involving claims for double taxation suffered on foreign dividends.
- for trusts in judgments involving tax interposition and gift and inheritance taxes.
Studio Legale Tributario Giordano Merolle has provided out-of-court advice to numerous companies, groups of companies, mutual funds, resident and nonresident individuals and professionals, offering customized and targeted solutions. Our expertise ranges from tax planning and corporate advice to the management of extraordinary transactions, with a pragmatic and strategic approach.
The firm has advised multinational companies, institutional investors, SMEs and individuals on issues including international tax planning, direct and indirect tax management, corporate reorganization transactions, from mergers and acquisitions to equity and business contributions.
Recent assignments include assisting:
- to aprivate university in the operation of transformation into a limited liability company.
- to a pension fund in establishing a real estate asset management vehicle.
- to a pension fund in structuring a vehicle for managing its securities assets.
- to a multinational group in its project to reorganize its permanent establishments and subsidiaries based in Italy.
- to an Italian bank on tax issues related to a securitization of consumer loans worth 6 billion euros.
- to a number of nonresident taxpayers in the submission of petitions for interpellation regarding the possibility of taking advantage of the preferential tax regimes for transferring residence to Italy.
- to a research consortium in the submission of an interpellation petition regarding its qualification as an IRES and IRAP taxable person.
- to numerous resident and nonresident individuals in resolving legal and tax issues related to estate and estate planning matters.
- to a multinational company in a mutual agreement procedure concerning a disputed issue between Italy and France.
- to an Italian industrial company in preparing an interpellation petition for the disapplication of loss carryover limits following a demerger.
- to numerous resident and nonresident companies and holding companies in various transactions of an extraordinary nature, such as equity acquisitions, contributions, mergers and demergers.
- to numerous taxpayers in the management and tax planning of generational transition and the establishment of trusts.
- To a group of companies in the reorganization of holdings held through contribution to a family holding company
