Evolutions in ascertainment methods, the use of ever-more detailed information sourced from data banks available to the Revenue, as well as the changed international climate, with a growth in collaboration agreements and taxation cooperation between States, have, in recent years, produced a refining of tax inspection, with inspections that are progressively more directed and specific to taxation problematics of both National and International relevance.
Our Firm has dealt with numerous disputes levelled by the Revenue on international themes, (relocations, stable organisations, transfer pricing, false tax residences, etc.) as well as national, with particular reference to the area of extraordinary corporate operations (leveraged buy outs, sales and transfers of companies, spin-offs). Our Firm works with professionals who combine high-level specific technical expertise with the ability to manage relations with the representatives of the Revenue.
The Firm assists the main players in the national and international market, in both the physiology of the relations with the Revenue (presentation of rulings, international rulings, requests for reimbursement) and in its pathology (tax inspections and greater scrutiny).
In this latter case the Firm assists its clientele from the start of the tax inspection, by managing the dialogue with the inspectors with the aim of limiting potential infringements liable to dispute to a maximum, analyses the outcomes and the disputes levelled by the Revenue, suggests the defensive strategy: all with the aim of placing the client in the condition to make informed choices, evaluating the cost/benefit relations between the extra-judicial composition of the dispute and the eventual evolution of the dispute.
In the pre-dispute step, the Firm assists its clientele by drawing up explanatory memoranda, starting up and managing the discussion stage with the Revenue, for the purpose of obtaining cancellation of the acts in internal review, discounts in mitigation, or pre-dispute definitions of the acts with tax settlement.
In disputes, the Firm takes on the role of client’s defence before all fiscal jurisdictions by taking charge of the drawing-up of the appeal, the completion and illustrative memoranda, counter-deductions, participation at hearings, closure of the judicial conciliation procedures, as well as compliance proceedings for forced execution of sentences in favour of the client.
The Firm further assists its clientele in the penal procedures deriving from infringements relating to tax laws.