Corporate International Taxation
Our specialists are committed to deal with any issue related direct and indirect international taxation in compliance with conventional law, multilateral treaties and EU Directives with particular reference to ECJ (European Court of Justice) rulings and OECD guidelines.
As international tax specialists, we provide those clients operating in an international environment with tax intelligence in order to decrease their worldwide tax liabilities while remaining fully compliant with current laws, tax regimes and any set of GAAR (general anti-avoidance rules).
Taxation of cross-border mergers and acquisitions
Our expertise covers any tax issues related to private equity transactions and company restructuring like mergers and acquisitions.
Our advise take into account the latest developments in international taxation for such operations in particular the implementation by most of OECD member countries of the recommendations on BEPS (Base Erosion and Profit Shift) and the related Multilateral Instrument (M.L.I.).
For both M&A and tax purposes we also produce due diligence reports providing analytic evaluation of your shareholding and company assets.
International tax planning
Our specialists are qualified to provide the best international structuring for small and middle sized entities wanting to operate in international environment.
We will advice you on the type of entity (company, partnership, joint venture, consortium, bare and discretionary trust) that suits the most to your needs and requirements at the group level taking into account tax implications in terms of direct and indirect taxes of your global operations.
Any tax planning will be structured also in light of the newly introduced international regulations in terms of reporting, beneficial ownership and economic substance of group entities and the new series of European directives like the Anti-tax avoidance Directives (ATAD 1 and 2) and the Base erosion and the Anti-abuse tax (BEAT) regime in the US.
Our ultimate goal is to mitigate your overall group taxation by structuring all your international group operations; we tailor our planning according to your industry and financing needs taking into account the nature of your group entities and their economic substance, whether the perform treasury, holding and sub-holding and special purpose functions in full compliance with both international and domestic anti-avoidance legislation.
We can help you to resolve any conflict related to residence and any tax residence issue arising as a result of company restructuring, mergers and acquisitions.
International tax compliance
We give advice on tax compliance requirements also providing supporting documentation to local tax authorities in order for you to take advantage of tax deductions, credit or exemption under European, conventional and local law like the Controlled Foreign Company which is included in Subpart F currently in force in the US and the Parent/Subsidiary, the Merger and the Interest and Royalties E.C. directives.
Our tax advisors can help you solving any issue related to juridical double taxation, interpretation of model tax conventions and the categorization of income for conventional purposes.
We help you to cope with practical difficulties in order to obtain a double taxation relief whether by credit or by exemption and eventually over-viewing the whole process towards a MAPs (Mutual Agreement Procedures) between the tax authorities.
Due diligence reporting
We commit to the best practice in drawing due-diligence reports for both tax and merger&acquisition purposes. We will provide you with a certified evaluation of your company equity and company assets by performing both financial and strategic analysis utilizing asset-based, multiples-based and discounted cash flow-based valuations where applicable.
Double Tax Treaty Passport
DTTP passport scheme enables taxpayers to receive dividends, interests and royalties from entities residing in the United Kingdom without the payer being liable to withhold tax. We deal with the British tax authorities (HMRC) in order to make you obtain a "double tax treaty passport" from the United Kingdom or from any other state where such regime is in place.