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Cross-border Tax

Managing international activities and operations is often complicated due to differences between tax and legal systems and the ways in which different tax authorities apply them. We cut through the red tape to help clients find the most commercial and cost-effective tax results.

We help inward investors in Italy and Italian companies in their overseas operations to identify the best and most commercially viable solutions and can advise in the following areas: 

Inward investment in Italy 

  • We provide tax assistance and news alerts on international tax matters
  • We provide feasibility studies and reviews of financial models
  • We analyse forms of investment (permanent establishments v. local companies, investment financing methods, etc.)
  • We analyse permanent establishment risk 
  • We advise on tax due diligence in acquisitions or sales
  • We advise on cash flow optimisation through analysis of financial flows and related forms of taxation at source 
  • We help to convert business models i.e.: commissionaire, limited risk distributor, toll and contract manufacturer, delocalisation (unilateral and multilateral agreements - APA, definition of new contracts, permanent establishment risk issues, transfer of tangible and/or intangible assets)
  • We consult on relation to costs incurred for parties resident in black-listed countries (preparation of applications for preventive tax clearance, analysis of existing commercial relationships and relative contracts, definition of documentation to support deductibility of the cost)

Italian investments abroad

  • We analyse foreign tax systems
  • We provide tax alerts on developments and changes in foreign tax systems
  • We analyse permanent establishment risk 
  • We advise on cash flow optimisation through analysis of financial flows and related forms of taxation at source
  • We advise on the impact of the controlled/associated foreign companies (‘CFC’) system and rules for the deduction of costs of black-listed parties
  • We help to plan tax structures on the basis of the group’s business model
  • We analyse of forms of investment (permanent establishments or local companies, investment financing methods, etc.)
  • We analyse and manage the tax obligations of foreign subsidiaries