Assistance in Tax Investigations

Assistance in Tax Investigations

The Firm provides assistance and defence to taxpayers in tax investigations and tax audits concerning abuse of law and CFC rules, as well as within cooperative compliance procedures, with the following objectives:

  • informing taxpayers of their rights and obligations and of the self-protection measures to be adopted in order to ensure the most effective exercise of their rights and the proper fulfilment of their obligations;
  • preventing challenges by reviewing the documentation to be submitted to the tax authorities and developing appropriate defence strategies;
  • ensuring that all relevant defence elements are properly recorded in the audit reports and that the related documentation is duly attached, also through direct interaction with the company’s personnel;
  • providing taxpayers and their representatives with technical assistance and verifying the accuracy of the official reports drafted by the tax authorities;
  • ensuring compliance with the limits and obligations set out in the Taxpayers’ Bill of Rights, as well as with statutory and constitutional provisions governing the exercise of the tax authorities’ investigative powers;
  • safeguarding fundamental rights, including personal freedom, confidentiality of correspondence, inviolability of domicile, and the right of defence, as guaranteed by the Constitution, the Charter of Fundamental Rights of the European Union, and the European Convention on Human Rights.

The Firm also provides assistance during on-site inspections at company premises, personal searches, the opening of safes, sealed envelopes or cabinets, access to company IT systems and email accounts, and the collection of data.

The Firm has assisted, and continues to assist, leading banking, corporate and insurance groups, both domestic and multinational, in tax investigation proceedings as well as in matters relating to corporate taxation and VAT.