The services provided by Studio Tributario Tognolo are organized by areas of expertise.
The professional leadership’s target are developed mostly with reference to consulting areas for medium and large companies, such as international tax law, domestic controversies and international procedures.
In addition to consulting services, the firm’s professionals participate to Conferences and Seminars supported by the professionals associations and by the most relevant players of the sector. They also write newsletters and articles on the main tax issues addressed to clients and to the most relevant magazines of the sector.
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You can find all our services in the section below.
- Bookkeeping (on request and provided in outsourcing);
- Predisposition of Statutory financial statements;
- Determination of the income taxes of the year on trial balances prepared either based on local GAAP or on IFRS;
- Deposit of Statutory financial statements and communications connected to company offices to the local Chamber of Commerce;
- Predisposition of communications to the Tax authorities and filing of the Italian tax returns;
- Predisposition and filing of communications and VAT returns to the tax authorities.
- Advice, opinions and legal opinions on domestic accounting, direct and indirect tax issues;
- Advice and opinions about national and cross-border VAT issues;
- Predisposition of legal opinions in Italian or English language on specific corporate tax and VAT aspects;
- Financial and treasury analysis;
- Deferred taxation aspects;
- Dialogue with the Italian tax authorities for the solution of corporate income tax and VAT aspects;
- Predisposition and submission of tax rulings to the Italian tax authorities;
- Advice to Italian holdings for the adoption of the enacted special tax regimes (consortium relief, worldwide and domestic consolidated tax regimes);
- Implementation of the Italian structures of multinational groups;
- Experienced assistance to the taxpayer during the tax audits carried on by
- the Italian Tax police (i.e. Guardia di Finanza) or
- the local Italian tax authorities (i.e. Agenzia delle Entrate)
- the Regional tax Office (i.e. Direzione Regionale delle Entrate)
- Assistance to taxprayers for the preparation and filing of tax claims to the tax courts;
- Assistance in the predisposition of the documentation necessary to benefit from the Patent Box regime and determination of the amount of the benefit;
- Assistance and representation of the company in front of the Ruling Office of the Italian Tax authorities to agree the methodology for the determination of the benefit.
- Tax planning and strategies connected to M&A transactions;
- Mergers, spin-off, share per share transactions, de-mergers, acquisitions, MBO and LBO transactions regarding Italian and foreign companies;
- Implementation of planned structures in Italy and in foreign countries, through the help of correspondent firms;
- Vendor & Buyer financial due diligences;
- Tax due diligences (data room and virtual data room);
- Tax due diligences related to IPO;
- Tax assistance to clients during all the deal (i.e. drafting of the MOU, definition of the warranties, drafting of the final contract).
- Assistance to foreign investors interested in developing a business activity in Italy, or the opposite;
- Accounting and tax assistance regarding real-estate transactions in Italy;
- Permanent establishment issues related to Corporate Income Tax or VAT;
- VAT refund procedures related to EU and extra-EU taxpayers;
- Analysis of bilateral treaties against double taxation and Treaty Shopping issues;
- International tax planning for Italian and foreign multinational groups;
- Reorganization of European multinational groups;
- Extraordinary EU transactions (such as mergers, de-mergers, share per share and contribution in kind);
- Filing request for the non-application of the CFC regime.
- Advice and assistance in transfer pricing issues;
- Assistance and predisposition of inter-company contracts, such as:
- Agency Agreements,
- Loan Agreements,
- Licensing Agreements related to trademarks–brands–patents and Know-How,
- Services Agreements,
- Cost Sharing Agreements,
- Contract manufacturing Agreements,
- Contract R&D Agreements,
- Supply Agreements,
- Distribution Agreements);
- Predisposition of comparability analysis and functional analysis for the definition of the arms’ length margin;
- Reorgnization of European multinational groups based on the Supply Chain analysis (i.e. Business restructuring - principal, contract manufacturer, commissionaire, instant buy/sell, contract distributor);
- Predisposition of Italian and European Benchmarking Analysis, with an in-depth check of the comparables;
- Assistance to companies in the collection of the documentation useful to prove the fairness of transfer pricing polices applied to I/C transactions;
- Assistance in the predisposition of the “Master file” and/or the “Country Specific documentation” as provided by the EU Code of Conduct;
- Assistance in the predisposition of the “Master file” and/or the “Country Specific documentation” as provided by the Italian Regulation number 2010/137654, dated September 29, 2010;
- Assistance and predisposition of Group Transfer Pricing Guidelines in agreement with OECD guidelines and/or European local tax law requirements;
- Assistance to the companies in the predisposition of the Country by Country reporting CbCR;
- Assistance in the predisposition of the documentation and representation of the company in front of Agenzia delle Entrate for the subsidy necessary for the Patent Box;
- Assistance in the predisposition of the international ruling and company's representation during the negotiation phase with Italian Authorities;
- Assistance to companies subject to a transfer pricing tax assessment in Italy or abroad;
- Assistance, predisposition and filing of the petition for the activation of the bilateral Advance Pricing Agreement A.P.A.;
- Predisposition of the Mutual Agreement Procedure M.A.P. according to art. 25 of the OCSE regulation;
- Assistance, predisposition and filing of the petition for the activation of the Arbitration Convention procedure n. 90/436/EEC.
- Experienced assistance to the taxpayer during the tax audits carried on by
- the Italian Tax police (i.e. Guardia di Finanza) or
- the local Italian tax authorities (i.e. Agenzia delle Entrate)
- the Regional tax Office (i.e. Direzione Regionale delle Entrate)
- Predisposition of legal opinions for tax litigation procedures;
- Comparative analysis of the different alternatives available to the taxpayer, tailor-made to the case under subject;
- Predisposition and deposit of self-protection petitions;
- Assistance and representation to the companies in the following procedures:
- Agreement to the preliminary tax reports;
- Gentlemen’ agreements with the tax authorities;
- Out of tax court settlements;
- Settlement before the tax court.
- Predisposition and deposit of memories within 60 days form the notification of the preliminary report;
- Assistance to taxprayers for the preparation and filing of tax claims to the tax courts;
- Assistance and representation to the companies in front of the tax courts, first (provincial) and second (regional) level;
- Predisposition of the petition for the suspension of the enforceable acts;
- Predisposition and deposit to the tax courts of claims and memories;
- Discussion in front of the tax courts during the public audiences;
- Assistance in the predisposition of tax reimbursement requests;
- Assistance and representation to the companies in the implementation of the International Ruling agreements (i.e. unilateral A.P.A.) procedure at the Rome Central Unit of the Italian tax authorities;
- Assistance and representation to the companies in the implementation of International procedures for the elimination of the double taxation, such as:
- EU Arbitration Convention procedure;
- Advance Pricing Agreements (APA);
- Mutual Agreement procedures (MAP).
- Appraisal activities connected to the following extraordinary transactions:
- Mergers;
- Purchase of going concern;
- Spin-off;
- Leverage by–out transactions (L.B.O.);
- Reorganization projects within multinational groups;
- Partisan technical expert and/or Court and tax Court appointed expert for the following topics:
- Financial Statements (civil and penal Court);
- Accounting principles;
- Transfer Pricing (registered expert at the Milan Tax Courts);
- International tax topics;
- Assistance in the phase preceding the admission to the composition with creditors:
- Requests for the admission to the composition with creditors;
- Certification of feasibility plans;
- Requests to the Court of composition with creditors.
- Court appointments such as:
- Judicial trustee;
- Official receiver;
- Judicial liquidator for winding up procedures declared by the Court;