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From a single question to ongoing management.

Six areas that hold together: a tax choice rarely has no corporate consequences, and vice versa. That is why we prefer to look at them together.

International taxation and residence

Tax residence is not chosen on a form: it is proved by facts. We analyse where effective management, economic interests and daily life actually are, compare domestic law with the applicable treaties, and build a documented, defensible position.

Companies

Tax residence and place of effective management
Foreign-dressing risk and evidence to rebut it
Permanent establishment, fixed and agency
CFC rules and controlled foreign companies
Taxation of dividends, interest and royalties

Individuals

Change of residence and AIRE registration
Residence file and tax residence certificates
Foreign income and assets, monitoring obligations
Double tax treaties
Preferential regimes for inbound and returning individuals

A change of residence works if it is real and documented. Before any step we rebuild the evidence file: that is where an assessment is won or lost.

Holdings, SPVs and corporate architecture

A holding company is not a tax advantage: it is a governance tool. It separates risk, regulates relations between shareholders and prepares an entry or an exit. We design it from the objective and test it in every country involved.

Design

Choice of jurisdiction and legal form
Italian, European and non-EU holding companies
SPVs for investments, real estate and transactions
Shareholders’ agreements and governance
Economic substance and presence requirements

Review

Analysis of existing structures and weak points
Intra-group flows and transfer pricing
Shareholder loans and capitalisation
Impact on banks and counterparties
Simplification of over-long chains

Much of our work is on structures that already exist: often the issue is not setting one up, but making safe what was set up years ago with different goals.

Ongoing tax and corporate advisory

For many companies the value is not in the exceptional opinion but in continuity: someone who knows the numbers, remembers the choices made and flags what is coming. That is the firm’s daily work.

Company

Ongoing tax advice and tax returns
Supervision of bookkeeping and financial statements
VAT, intra-EU transactions, reverse charge
Advance review of transactions and contracts
Corporate filings and minutes

Shareholders and directors

Remuneration, dividends and distributions
Personal tax position of shareholders
Directors’ liability
Related-party transactions
Relations with banks and lenders

The scope of an ongoing engagement is set out in writing: what is included, what is billed separately, who does what. No grey areas.

Corporate transactions and succession

In corporate transactions value is created or destroyed in the detail: how a clause is drafted, how a tax risk is estimated, how the consideration is structured. We assist throughout, in coordination with legal counsel.

Transactions

Tax and accounting due diligence
Mergers, demergers, contributions, disposals
Business and share valuations
Structuring of price and warranties
Support in negotiations and at signing

Family and business

Generational transition and family agreements
Family holding companies and governance between branches
Gifts, inheritance and indirect taxes
Protection of personal assets
Exit of a shareholder and liquidations

A generational transition is not a deed, it is a path of several years. The earlier it starts, the wider the options and the lower the cost.

Rulings, tax audits and litigation

When an audit arrives, the room for manoeuvre depends on how the position was built in the preceding years. We step in at every stage: to prevent, to clarify in the adversarial phase, or to defend before the tax courts.

Prevention

Rulings and applications to the authorities
Advance opinions on risk-sensitive transactions
Rebuilding the documentary record
Voluntary regularisation and settlement schemes
Monitoring of critical positions

Defence

Assistance during audits and inspections
Adversarial phase and defence submissions
Settlement with the authorities and conciliation
Appeals before the tax courts
Management of penalties and collection

In tax disputes timing is everything: deadlines are short and strict. If you have received a notice, the first useful step is to let us read it immediately.

UAE desk and cross-border projects

We have worked in the Emirates since 2007. Our role is to hold both sides of the project together: the local structure, with its licence, visas and filings, and the consequences at home, where it is decided whether that structure holds.

UAE side

Incorporation in Free Zone and Mainland
Residence visas, Golden and Green Visa
Corporate Tax, VAT and EmaraTax
Local bookkeeping and compliance
Bank account opening and due diligence

Home side

Foreign-dressing, CFC rules, permanent establishment
Change of residence for individuals
Taxation of outbound dividends
Foreign asset monitoring and reporting
Coordination with the local provider

In the Emirates we work with OutstandingLife Group: Outstanding Life International for corporate services and Outstanding Tax & Accounting for local accounting and tax. One project, two points of oversight.

Frequently asked questions

What clients ask us most often

How does the first contact work?

You write or call and we arrange a meeting, at the office or by video call. It is there to understand your situation and tell you whether and how we can help. At the end you receive, in writing, an outline of the work required and the fee. The first meeting carries no obligation.

How are fees determined?

It depends on the engagement. For opinions and transactions we agree a fixed fee based on the defined scope; for ongoing assistance, a periodic retainer. In both cases the fee is agreed before we start: we do not invoice for work that was not authorised.

Do you work with clients who already have an accountant?

Yes, and it is an important part of our work. We are often called on a specific matter — a transaction, a foreign structure, an assessment — and coordinate with the professional who handles day-to-day compliance. We never ask anyone to change their advisers.

Do you act for clients outside Milan?

Yes. The firm is based in Milan and works regularly in London, Lugano, Moscow and Dubai; many engagements are handled entirely remotely, with documents exchanged securely and meetings by video call. Where local presence is needed we rely on trusted professionals on the ground.

Can you assist me if I move abroad?

It is one of our core areas. We assess the consequences of the move in advance, handle the filings and, above all, build with you the file that proves effective residence: that is what counts if your position is challenged.

What languages do you work in?

Italian and English, including on technical matters and in correspondence with foreign advisers and authorities.