Cross-border Tax | Fieldfisher
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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.

Why work with our Cross-border Tax lawyers?

Our international tax experts have unparalleled experience in advising clients on cross-border tax issues both in Italy and abroad.  We have developed a methodological approach aimed simplifying complex issues, ensuring the expectations of parent companies are in line with the local operations in various countries.

Working in groups, we advise and coordinate the overseas taxes of companies and permanent establishments abroad, at all stages of operations. This includes; analysing the most effective form of investment, examining the appropriateness of contracts, company organisation. economic scenarios to minimise the risk of disputes, and optimising the tax terms by reorganising the supply chains to different market conditions. We adopt a similar for foreign investors in Italy, focussing in particular on our knowledge of various industries in order to exploit the respective tax advantages.

Daily coordination with other teams in the firm ensures know-how is shared and enables us to provide our clients with integrated knowledge on all tax issues.

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
see full team