Paolo Tognolo

Senior Partner and founder

Senior Partner at STUDIO TRIBUTARIO TOGNOLO (estabilished by him in November, 2002), he got his Economic’s degree as Tax Consultant at Bocconi University of Milan.

He is a member of the State tax consultants association from 1992 (Dottori Commercialisti) and a member of the State Chartered Accountant association (authorising to perform the activity of Statutory Auditor of Italian legal entities).

He is also included in the Register of technical consultants of the Milan tax Courts as expert of international tax matters.

He regularly provides tax advice to several Italian multinational groups and helps a trustful support to foreign multinational groups on Italian and international tax matters. He also performs the statutory auditor’ legal control activities for many relevant Italian legal entities. He is widely experienced in:

• M&A (structuring and tax due diligence) and IPO (tax side).
• Streamlining projects and reorganization of European groups;
• International tax treaties and double taxation aspects;
• Permanent Establishment;
• Transfer Pricing (group planning, defence, documentation, benchmarking analysis, unilateral APA, bilateral APA, Patent box regimes);
• Back-office assistance to companies during the assessment performed by tax authorities and following steps at domestic as well international implications (i.e. EU arbitration convention procedures and Mutual Agreement Procedures);
• Standard Ruling and Ruling for New Investments;
• Group business reorganisations (economic analysis, transfer pricing aspects, direct and indirect tax consequences);

Paolo Tognolo is member of International Tax Commission of the Milan’s Tax Consultant associations and he regularly partecipates as relator to Conferences and Matsters organized by the tax law school of the Tax Consultant’s foundation of Milan. He’s also a member of the Company law Board of Assolombarda, of B.I.A.C. (the Business and Industry Advisory Commitee to the OECD) and partner of I.F.A. (International Fiscal Association).

He regularly lectures at external courses, seminars and workshops for several domestic and international organisations on domestic and international tax matters (such as Business International, Sole 24 Ore, International Institute of Research, Learning Resources Associate and Cegos) and at masters in international taxation (CERTI-Bocconi University, Centro Studi Ragionieri and CEGOS).

He’s author and co-author of:

“Le perizie valutative quale supporto fiscale al prezzo delle transazioni”, AA VV, I Quaderni AIAF, number 155, Milan, March 2013

“La stabile organizzazione”, edited by Il Sole 24 Ore, 2004.

“E-commerce e fisco” with Ciacci, Meazza, Piazza e Santacroce, edited by Il Sole 24 Ore, 2001.

“Guida all’E-commerce”, AA VV, Le guide Operative di Guida Normativa , edited by Il Sole 24 Ore, May 2000

“Le imposte differite nella prassi italiana e internazionale” with Lia Treichler, edited by CEDAM, October 1996.

Several publications on most authoritative Italian and International tax magazines and newspapers (such as BNA, IBFD, Sole 24 Ore, Italia Oggi, Corriere Tributario, Guida Normativa, Tax Planning, Il Fisco) concerning Italian and international tax matters (Transfer Pricing, Permanent establishment, OECD Model treaty, E-commerce, Parent-subsidiary EU Directive, Group companies taxation in EU, CFC and Cross-border sales of Software, etc.).

Comments sent to the OECD

• Comments to Draft Action 14 – “Make dispute resolution mechanism more effective” – sent on January 16, 2015
• Comments to Draft Action 10 – “Low value-adding intragroup services” – sent on January 13, 2015

Articles before 2016

Seminars