International taxation

The activity consists of assisting clients with all the typical cases falling under international taxation

This may primarily concern Italian companies with foreign subsidiaries or branches that fall under the regime of controlled foreign companies pursuant to article 167 of the Consolidated Act on Income Tax (TUIR). Another case is that of Italian branches of foreign entities for which we provide global assistance on matters related to direct and indirect national taxation. We also assist Italian companies with permanent establishments abroad on accounting reporting issues and the related tax implications in Italy of such foreign entities. We also provide assistance to foreign entities with regard to issues such as effective tax residence or offshoring, through a regulatory, practice and case-law analysis of these cases. Finally, the analysis is also aimed at the so-called black list costs that were reintroduced by the 2023 budget law in relation to transactions of goods and services with certain countries.