Tax Advisory for Legal Entities

Companies operating internationally face more complex taxation than purely domestic businesses: different rules across jurisdictions, risks of double taxation, specific reporting obligations, and increased scrutiny from tax authorities on transfer pricing and potentially abusive structures.

We provide corporate tax advisory to Italian companies operating abroad, foreign companies with interests in Italy, and multi-jurisdictional structures.

VAT for professionals and businesses

Proper VAT management—especially in cross-border transactions—requires careful attention: place of supply rules, reverse charge mechanisms, pro-rata calculations, and special regimes. We ensure correct VAT treatment and assist in disputes or reassessments.

Permanent establishment

Permanent establishment is the key criterion used by a country to tax the income of a foreign company. Having a physical presence, agent, or even continuous activity in Italy may trigger Italian tax obligations.

We assess operational structures to determine whether a permanent establishment exists and its implications in terms of corporate tax (IRES) and compliance.

Branch of a foreign company

Opening an Italian branch of a foreign company is an alternative to establishing a subsidiary. It carries specific tax implications—profit attribution, accounting obligations, and parent company relations.

We assist in choosing the most efficient structure, setting up the branch, and managing ongoing tax compliance.

Transfer Pricing

Transactions between group companies in different countries must comply with the arm’s length principle. Non-compliance may lead to significant tax adjustments in multiple jurisdictions.

We assist in preparing transfer pricing documentation, defining intercompany pricing policies, and handling tax audits.

International tax planning

For international groups, tax planning involves selecting the appropriate legal structure, allocating functions and risks, and managing flows of royalties, interest, and dividends.

We design efficient, defensible structures aligned with Italian and EU anti-avoidance rules—without exposing clients to legal or reputational risks.