THE FIRM
Foglia & Partners is a boutique firm specialised in tax matters, based on the specialist skills, experience and strong client focus of its associates. The Firm was established in January 2016 with the aim of representing a reference in tax advisory, particularly in the field of corporate taxation, both in the ordinary course of business and in relation to reorganisation and acquisition transactions, international, financial and real estate taxation, the taxation of individuals and wealth, transfer pricing as well as tax litigation.
Foglia & Partners is permanently listed in the prestigious “Chambers Europe” ranking in the Tax sector. Moreover, the Firm has received several important awards, including (i) the Professional of the Year in Tax Advisory Award for 2022, (ii) the Firm of the Year in Cooperative Tax Compliance Award for 2021, (iii) the Best Practice "Tax Litigation" Award for 2018, (iv) the Best Practice “Financial Taxation" Award for 2017 and (v) the “Emerging Firm" Award for 2016, at the Legalcommunity Tax Awards, as well as (vi) the Le Fonti award as Excellence Boutique of the year 2016 in Taxation, among the most important awards in the market of tax and tax advisory services in Italy.
The firm continues to have strong growth prospects and relies on its specialised professionals, who constantly keep up-to-date, also by participating in study committees and, as speakers, in several professional programmes and specialisation seminars.
THE TEAM
PRACTICE AREAS
With its specialised expertise in domestic and international tax matters, Foglia & Partners offers advice in all the main areas of domestic and international tax law, supporting clients in the more complex strategic and management decisions.
Corporate Taxation
Foglia & Partners assists clients by providing advisory services on tax issues related to day-to-day ... business management with a focus on assistance aimed at the correct calculation of the tax burden and the due fulfillment of tax obligations. Through a continuous and on-going contact with the companies’ management, the Firm’s professionals deal with all aspects of corporate taxation, including the issuance of opinions on specific tax matters, advisory on the determination of the tax burden and on the revision of tax returns. The continuous attention paid to regulatory developments allows the Firm to offer professional and prompt updates and to provide clients with the tools and the most appropriate solutions to best manage tax issues. In this context, Foglia & Partners advises, on an ongoing basis, leading national and international companies with hundreds of millions of Euro in turnover. In addition, Foglia & Partners, in the framework of this activity, has submitted, on behalf of its clients, several ruling requests to the Italian Tax Authority for very complex issues aimed at identifying new and innovative solutions.
Foglia & Partners assists clients by providing advisory services on tax issues related to day-to-day ... business management with a focus on assistance aimed at the correct calculation of the tax burden and the due fulfillment of tax obligations. Through a continuous and on-going contact with the companies’ management, the Firm’s professionals deal with all aspects of corporate taxation, including the issuance of opinions on specific tax matters, advisory on the determination of the tax burden and on the revision of tax returns. The continuous attention paid to regulatory developments allows the Firm to offer professional and prompt updates and to provide clients with the tools and the most appropriate solutions to best manage tax issues. In this context, Foglia & Partners advises, on an ongoing basis, leading national and international companies with hundreds of millions of Euro in turnover. In addition, Foglia & Partners, in the framework of this activity, has submitted, on behalf of its clients, several ruling requests to the Italian Tax Authority for very complex issues aimed at identifying new and innovative solutions.
Extraordinary transactions, Business Restructuring and M&A
The Firm assists its clients in planning corporate acquisitions and reorganisations, including cross-border transactions.... With particular regard to acquisitions, the activity is focused on the due diligence phase, the analysis of the tax consequences of different alternatives, the assistance in the negotiation with counterparties and in the implementation phase. As part of this activity, Foglia & Partners has assisted its clients (both buyers and sellers) in important transactions, taking care of both due diligence and contractual aspects. The Firm's professionals have also gained significant expertise in listing transactions, mergers, demergers, spin-offs, liquidations, takeover bids, corporate reorganisations and restructurings amongst others; through share exchanges or transfers of businesses.
The Firm assists its clients in planning corporate acquisitions and reorganisations, including cross-border transactions.... With particular regard to acquisitions, the activity is focused on the due diligence phase, the analysis of the tax consequences of different alternatives, the assistance in the negotiation with counterparties and in the implementation phase. As part of this activity, Foglia & Partners has assisted its clients (both buyers and sellers) in important transactions, taking care of both due diligence and contractual aspects. The Firm's professionals have also gained significant expertise in listing transactions, mergers, demergers, spin-offs, liquidations, takeover bids, corporate reorganisations and restructurings amongst others; through share exchanges or transfers of businesses.
Financial taxation
The Firm offers specific expertise regarding the applicable tax regime to all main extraordinary finance transactions... : issuance, placement and listing of financial instruments (shares, bonds, minibonds) on regulated markets; granting of medium/long-term loans; structured finance transactions; securitisations; factoring. In this area, the Firm also assists issuers and intermediaries involved in the placement of financial instruments in the preparation of prospectuses and Offering Circulars. Regarding financial taxation, the Firm's professionals have gained significant experience assisting some of the main players in the financial sector (banks, securities, real estate fund management companies, private equity, and venture capital funds) and industrial companies, in both national and international structured finance and capital markets transactions. In this context, Foglia & Partners has been involved in several capital market transactions.
The Firm offers specific expertise regarding the applicable tax regime to all main extraordinary finance transactions... : issuance, placement and listing of financial instruments (shares, bonds, minibonds) on regulated markets; granting of medium/long-term loans; structured finance transactions; securitisations; factoring. In this area, the Firm also assists issuers and intermediaries involved in the placement of financial instruments in the preparation of prospectuses and Offering Circulars. Regarding financial taxation, the Firm's professionals have gained significant experience assisting some of the main players in the financial sector (banks, securities, real estate fund management companies, private equity, and venture capital funds) and industrial companies, in both national and international structured finance and capital markets transactions. In this context, Foglia & Partners has been involved in several capital market transactions.
Litigation and ruling procedures
The Firm assists its clients during tax inspections ... carried out by the Italian Tax Authority and the Tax Police (Guardia di Finanza), in the pre-litigation phase, with particular reference to the preliminary adversarial procedure and the preparation of defence briefs, as well as in the settlement procedure. The Firm's professionals have gained consolidated experience in managing relations with the tax authorities and in the defence, on behalf of leading clients, in domestic and international tax disputes in highly complex cases. The Firm's litigation department supports clients in tax disputes with the utmost care during all stages: both in the initial stages of inspections and in the various stages of litigation. The beginning of the tax litigation and its development in all phases, from the first instance to the Supreme Court judgement, are followed with “tailored” care, defining the defensive strategies on the basis of a deep knowledge of both the relevant substantive issues and all strictly procedural aspects. As part of this activity, Foglia & Partners assists its clients in court and out-of-court proceedings on very complex issues and very significant amounts.
The Firm assists its clients during tax inspections ... carried out by the Italian Tax Authority and the Tax Police (Guardia di Finanza), in the pre-litigation phase, with particular reference to the preliminary adversarial procedure and the preparation of defence briefs, as well as in the settlement procedure. The Firm's professionals have gained consolidated experience in managing relations with the tax authorities and in the defence, on behalf of leading clients, in domestic and international tax disputes in highly complex cases. The Firm's litigation department supports clients in tax disputes with the utmost care during all stages: both in the initial stages of inspections and in the various stages of litigation. The beginning of the tax litigation and its development in all phases, from the first instance to the Supreme Court judgement, are followed with “tailored” care, defining the defensive strategies on the basis of a deep knowledge of both the relevant substantive issues and all strictly procedural aspects. As part of this activity, Foglia & Partners assists its clients in court and out-of-court proceedings on very complex issues and very significant amounts.
Real estate taxation
The firm has specialised expertise in real estate taxation and in particular, in all tax aspects ... relating to the transfer of real estate and property rights in general. The Firm's professional activity regards all phases of real estate transactions, from the structuring phase of purchases and sales of real estate and building areas, to the negotiation phase with counterparties. The Firm's professionals have also gained significant experience in the taxation of real estate funds, with particular reference to issues related to the acquisition, contribution of real estate, disinvestment and placement. In particular, Foglia & Partners has worked with some of the leading domestic and international real estate operators, with respect to acquisitions, leasing, financing, divestments, creation of real estate funds under Italian law and SIIQ, etc.
The firm has specialised expertise in real estate taxation and in particular, in all tax aspects ... relating to the transfer of real estate and property rights in general. The Firm's professional activity regards all phases of real estate transactions, from the structuring phase of purchases and sales of real estate and building areas, to the negotiation phase with counterparties. The Firm's professionals have also gained significant experience in the taxation of real estate funds, with particular reference to issues related to the acquisition, contribution of real estate, disinvestment and placement. In particular, Foglia & Partners has worked with some of the leading domestic and international real estate operators, with respect to acquisitions, leasing, financing, divestments, creation of real estate funds under Italian law and SIIQ, etc.
International taxation
Foglia & Partners provides advice on all issues concerning direct and indirect taxation in cross-border contexts ... . In particular, the Firm's activity relates to the tax regime of income produced abroad by subjects resident in Italy and of income produced in Italy by subjects resident abroad for tax purposes, as well as the planning and the analysis of tax effects of cross-border reorganisations of Italian and foreign multinational groups. The Firm assists its clients in the context of advance ruling procedures concerning, entry and exit values in case of transfer of residence; requirements for setting up a permanent establishment in Italy and the determination of the relevant income; conventional/EU regimes applicable to transnational flows of dividends, interest and royalties. As part of this activity, Foglia & Partners has dealt with the planning and verification of the flows of the main commercial and financial transactions of very complex groups operating in different countries.
Foglia & Partners provides advice on all issues concerning direct and indirect taxation in cross-border contexts ... . In particular, the Firm's activity relates to the tax regime of income produced abroad by subjects resident in Italy and of income produced in Italy by subjects resident abroad for tax purposes, as well as the planning and the analysis of tax effects of cross-border reorganisations of Italian and foreign multinational groups. The Firm assists its clients in the context of advance ruling procedures concerning, entry and exit values in case of transfer of residence; requirements for setting up a permanent establishment in Italy and the determination of the relevant income; conventional/EU regimes applicable to transnational flows of dividends, interest and royalties. As part of this activity, Foglia & Partners has dealt with the planning and verification of the flows of the main commercial and financial transactions of very complex groups operating in different countries.
Cooperative compliance, enhanced cooperation and tax incentives
The Firm's professionals have consolidated experience in the management ... of advance and continuous interlocutions with the Tax Authorities within the framework of special regimes provided for by the legal system, aimed at establishing a regime of enhanced cooperation (known as 'cooperative compliance regime') or at obtaining certain tax benefits granted by the domestic legislation (e.g., agreements within the framework of the 'patent box' favorable regime). In this context, Foglia & Partners has, inter alia, supported certain taxpayers throughout the process of (a) admission to the “cooperative compliance regime”; (b) definition, on adversarial basis, of the methods and criteria for determining the taxable income for the purposes of the “patent box” regime.
The Firm's professionals have consolidated experience in the management ... of advance and continuous interlocutions with the Tax Authorities within the framework of special regimes provided for by the legal system, aimed at establishing a regime of enhanced cooperation (known as 'cooperative compliance regime') or at obtaining certain tax benefits granted by the domestic legislation (e.g., agreements within the framework of the 'patent box' favorable regime). In this context, Foglia & Partners has, inter alia, supported certain taxpayers throughout the process of (a) admission to the “cooperative compliance regime”; (b) definition, on adversarial basis, of the methods and criteria for determining the taxable income for the purposes of the “patent box” regime.
Wealth management
The Firm's professionals, among other things, have gained significant experience in assisting ... leading clients in estate planning, generational transitions and asset protection (e.g., family pacts, etc.). The Firm is able to offer assistance on the establishment of trusts and the assessment of the taxation of structured products. In the context of this activity, Foglia & Partners has assisted several clients in relation to procedures for the voluntary disclosure of assets abroad, planning in-life generational transitions through multiple instruments such as, for example, trusts and partnerships, as well as in liaising with the tax authorities in court and out-of-court procedures concerning the tax residency and the application of double taxation conventions.
The Firm's professionals, among other things, have gained significant experience in assisting ... leading clients in estate planning, generational transitions and asset protection (e.g., family pacts, etc.). The Firm is able to offer assistance on the establishment of trusts and the assessment of the taxation of structured products. In the context of this activity, Foglia & Partners has assisted several clients in relation to procedures for the voluntary disclosure of assets abroad, planning in-life generational transitions through multiple instruments such as, for example, trusts and partnerships, as well as in liaising with the tax authorities in court and out-of-court procedures concerning the tax residency and the application of double taxation conventions.