International taxation and residence
Tax residence, double tax treaties, permanent establishment, CFC rules and foreign-dressing: where you are taxed, and why.
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Chartered accountants · Milan, Europe and beyond
The tax and corporate decisions that matter deserve proper guidance. We have been giving it for forty years.
Since 1985 we have advised companies, groups and families on decisions that cross borders: where to place a holding company, how to structure an investment, how to move a business or a family estate without surprises. One point of contact, from the first analysis to signing.
- ODCEC Milan since 1985
- International tax and holding structures
- Milan · London · Lugano · Moscow · Dubai
How an opinion is builtExample
FramingActivity, structure, countries involved
CompletedLegal analysisDomestic law, treaties, practice
CompletedComparing the optionsCosts, risks and timing side by side
In progressImplementation and supportDeeds, filings, monitoring
PlannedRUAn opinion is never an abstract document: it comes with the recommendation, the timing and the cost.
- Forty years in practiceRegistered with ODCEC Milan since 1985
- Five locations, one point of contactMilan, London, Lugano, Moscow and Dubai
- Holdings, SPVs and groupsCorporate structures designed to last
- Strict confidentialityProfessional discretion on every piece of data and document
Who we work for
Two different starting points, the same need: to decide with full knowledge of the facts.
Whether you run a business or govern a family estate, the problem is the same: understanding the consequences of a choice before you make it.
Companies and groups
Companies, groups and investors
We work alongside you when the business grows, enters new markets or changes shape: every step is assessed from the tax, corporate and financial angle at the same time.
- International expansion and foreign establishments
- Italian and foreign holding companies, investment SPVs
- Reorganisations, mergers, demergers, disposals
- Transfer pricing and intra-group dealings
- Tax residence, permanent establishment, CFC rules
Individuals and families
Individuals and family wealth
A change of residence, a generational transition or an investment abroad deserve the same care as a corporate transaction. Often more.
- Change of tax residence and AIRE registration
- Taxation of foreign income and assets
- Generational transition and asset protection
- Repatriation of activities and voluntary regularisation
- Dealings with the tax authorities
Why tax oversight matters
The rules have converged. The scrutiny has multiplied.
Automatic exchange of information, transparency obligations, common anti-avoidance rules: a corporate choice must now be read in every country it touches, not only where it starts.
1985
Year of registration with the Order of Chartered Accountants of Milan
40+
Years of practice in international taxation and corporate structuring
5
Core locations: Milan, London, Lugano, Moscow, Dubai
IT / EN
Working languages with clients and their advisers
The information on this website is general in nature and does not replace professional advice: rules, rates and conditions must be verified case by case.
What we do
Six areas of work, one coordinating hand.
You can bring us a single question or hand over the ongoing management of your tax and corporate position. Either way, scope, timing and fees are agreed before we start.
Holdings, SPVs and corporate architecture
We design and review corporate chains, holding companies and dedicated vehicles, so that the structure follows the business plan and not the other way round.
Read moreOngoing tax and corporate advisory
Day-to-day assistance on returns, accounts, filings and corporate matters, with a stable contact who knows your history.
Read moreCorporate transactions and succession
Acquisitions, disposals, mergers, contributions and business transfers, from due diligence to signing.
Read moreRulings, tax audits and litigation
From a request for a ruling to the defence in court: we represent you in your dealings with the tax authorities.
Read moreUAE desk and cross-border projects
For those looking at the United Arab Emirates: a single point of oversight between Italy and the UAE, with the OutstandingLife group companies on the ground.
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Our approach
Understand first, advise second. Never the other way round.
There are no standard solutions: there is your business, with its real activity, its shareholders, its countries and its numbers. Every opinion starts there, not from a template.
Our work does not end with the technical document. We explain what each option involves, what it costs, which risks it opens and which it closes, so that the decision remains yours — taken with all the information in hand.
And once the choice is made, we stay: filings, dealings with counterparties and monitoring over time are part of the engagement, not a separate chapter.
- Substance before form
- A single point of contact
- Fees agreed in advance
- Coordination with your advisers
- Confidentiality without exceptions
Independence
Analysis and recommendations in the client’s sole interest, free of conflicts.
Prudence
We prefer a defensible structure to a clever one. Risk is assessed, not taken.
Clarity
Scope, timing and fees explained before we begin. No surprises.
Continuity
We stand behind our work and remain alongside you afterwards.
Our method
Five steps, no surprises
The same path for a single opinion and for an ongoing engagement: the duration changes, the rigour does not.
Framing
We review the activity, corporate structure, countries involved, accounts and goals.
Document collection
We request deeds, accounts, contracts and returns in an orderly way.
Technical assessment
We identify obligations, risks, opportunities and viable options.
Recommendation
We present the recommended solution, with costs, timing and alternatives.
Implementation and oversight
We handle deeds and filings and monitor the position over time.
“A corporate structure holds up if it holds up to the facts: the activity it carries out, the people who govern it, the documents that support it. The rest is architecture on paper.”
Dott. Raffaele Umbriano · Chartered Accountant