International and European Union taxation

"The increasing globalization of the markets has compelled not only multinational groups which, by definition, work in an international environment, but also individuals and domestic companies to operate in foreign jurisdictions meaning that international taxation matters need be constantly addressed. As a result, international tax planning has become more and more important for the creation of value for the shareholder and is now one of the most technically complex areas for both the large and the so-called ‘pocket-sized’ multinational corporations."

Legalitax, supported by its international network of firms leading experts in their fields, provides its multinational clients and international investors with innovative proposals, at a global level, for their cross-border transactions and with practical advises solving the conflicts of tax laws in various jurisdictions.

Legalitax’s specialization in this field includes:

  • Planning and implementation of reorganization plans for Italian groups with overseas operations and foreign groups working in Italy
  • Identification of the most tax efficient methods for both outbound and inbound cross-border acquisition transactions
  • Drafting of tax  questioning  in order not to apply specific regulations (Controlled Foreign Companies, black list, non-deductible costs, dividends earned from blacklisted sources, losses carried forward and interest payable in connection with extraordinary transactions)
  • Application and interpretation of International Conventions on International Double Taxation
  • Assistance in  international ruling procedures
  • Advise on EU tax law matters
  • Advise on  policies to set transfer prices
  • Drafting of local supporting documentation
  • Assistance in drafting national rulings on transfer price issues and permanent establishments

In addition to international tax assistance on  cross-border transactions, we also assist clients in any possible tax authority investigation (by the Guardia di Finanza tax department of the Italian police force or the Agenzie delle Entrate - the Italian Revenue Agency), assisting them before Tax Courts.