Tax

CTL provides tax assistance and consulting with reference to ordinary and extraordinary transactions, including:

Taxation for companies and corporate groups, including financial and real estate groups:

• Assistance in calculating payable tax amounts
• Assistance with Italian and international tax consolidation (registration, consolidation, drawing up the “CNM” model)
• Providing opinions and writing tax requests aimed at interpreting and applying the law, both at national and international level
• Specific tax consulting for entities that adopt IAS/IFRS accounting standards and for financial institutions and banks
• Tax consulting on tax issues regarding transactions in the real estate and renewable energy sector
• Consulting and assistance on how to access low-tax regimes, including those relating to intellectual property, innovative start-ups and innovative SMEs, as well as cooperative compliance
• Tax assistance for holding companies, particularly regarding the tax register, CRS and FATCA
• Check-ups for direct taxation purposes

Company reorganisations and M&A:

• Tax consulting in the field of Italian and cross-border company reorganisations, mergers and acquisitions
• LBOs and MBOs as well as the circulation of intellectual property
• Transferring residence out of Italy (so-called “exit tax) and into Italy (so-called “entry tax”)
• Assistance to complete consulting procedures with the relevant tax authorities connected with extraordinary transactions

Transfer pricing, Patent Box, “MAP” and “APA”:

• Assistance regarding transfer pricing
• Assistance with reference to tax breaks relating to intellectual property, including the patent box
• Consulting and assistance regarding the “MAP” (Mutual Agreement Procedure) and “APA” (Advanced Pricing Agreement)

International tax law:

• Assistance with reference to the application of treaties against double taxation
• Consulting relating to changes deriving from the OECD and BEPS action plan
• Preparing notifications of tax incompatibility to the EU Commission
• Judicial assistance in the EU Court
• Assistance for tax management of foreign assets (preparation of the RW form)
• Assistance regarding tax residence and the subsequent management of compliance activities in Italy and abroad

Generational transitions, taxation of assets, trusts and asset protection :

• Consulting and tax advice in the context of generational transitions, both in Italy and abroad
• Taxation on trusts and restrictions on use
• Tax consulting aimed at asset protection regarding tax residence and the subsequent management of compliance activities in Italy and abroad

Taxation of natural persons:

• Consulting and tax advice in relation to establishing tax residence in Italy or transferring residence abroad, with a particular focus on applicable low-tax regimes
• Tax assistance with reference to real estate transactions and carrying out investments in Italy or abroad (works of art, aeroplanes, boats, etc.)

Taxation relating to employees:

• Tax assistance for management pay packages
• Analysis and consulting regarding fringe benefits and corporate welfare
• Tax consulting in relation to so-called “expatriates”

VAT:

• Tax assistance and consulting with reference to VAT issues in Italy and abroad
• Tax assistance and consulting regarding real estate and financial transactions
• Assistance regarding group VAT (applying the taxation system, periodic liquidations, preparing official declarations, etc.)
• Assistance regarding the VAT tax representative and direct identification of foreign entities, also taking on the role of tax representative for non-EU entities through official appointment
• Assistance regarding imports and exports, deferred payment of customs duties (also VAT)
• Assistance regarding reimbursement requests for direct and indirect taxes (VAT) in Italy and abroad
• VAT check-up

Assistance prior to and in relation to disputes:

• Assistance during procedures to spontaneously regularise tax violations
• Assistance and representation during procedures to request tax refunds
• Assistance during tax audits
• Assistance and consulting during inspections and with reference to measures to mitigate the dispute
• Tax assistance, representation and defence throughout all stages of the tax dispute