Our Firm provides advisory and representation services through the preparation of studies and legal opinions, as well as through expert advocacy in tax ruling procedures and at all stages of tax litigation, from the Tax Courts to national and European High Courts, with respect to the taxation of individuals, including:
- identification of the tax residence of natural persons based on the provisions of the TUIR and the tie-breaker rules provided under applicable tax treaties;
- tax relief regimes available to individuals transferring their tax residence to Italy;
- eligibility for foreign tax credits in respect of taxes paid abroad and their calculation;
- reporting obligations concerning foreign financial assets and investments in the RW section;
- taxation of income derived from land or buildings located in Italy or abroad, as well as the direct and indirect taxation of real estate transfers and the applicable reduced tax rates; recalculation of the market value of land and buildings;
- taxation of interest income; taxation of dividends deriving from withdrawals, capital reductions, distributions of reserves or liquidations, as well as other capital gains; taxation of shareholdings, gains from derivative contracts, and short-term financial or non-financial transactions;
- taxation of licenses granted by companies to their shareholders and determination of the relevant arm’s length value;
- taxation of income earned by artists and sports professionals, including where they are contractually linked to companies, under both domestic and international tax rules;
- taxation of income derived from trademarks, copyrights, patents and other intangible assets, including image rights and personality rights;
- reorganization of family assets and intergenerational wealth transfers;
- the tax regime applicable to transfers and transactions involving shareholdings that result in the acquisition of control.
Additionally, the Firm provides advice and assistance in identifying the most tax-efficient structures for the acquisition and management of real estate, financial activities and intangible assets.
