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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.

A first conversation, no commitment

Tell us about your situation. We will explain clearly what is needed, with what timing and at what cost.

A first meeting is there to establish whether we can be useful to you. No fixed packages, no obligation: an honest picture of the work involved.