PRACTICE AREAS
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 an ongoing relationship with management and a constant focus on regulatory developments, the Firm offers timely professional updates and provides clients with the most appropriate tools and solutions to best manage tax issues, including through the drafting of memoranda and opinions as well as in ruling procedures.
In this context, Foglia & Partners advises, on an ongoing basis, leading national and international companies, including listed ones.
Foglia & Partners assists private clients in estate planning, generational transitions and asset protection (e.g. family pacts; etc.).
Advising HNWIs, the Firm has gained strong experience regarding the beneficial regimes provided for individuals who transfer their residency to Italy.
Moreover, the Firm’s professionals habitually deal with the set-up of trusts, the evaluation of the taxation of structured products, and the planning of in-life generational transitions.
Foglia & Partners assists clients with regard to all corporate reorganisation, including cross-border transactions.
The Firm manages the tax profiles of all phases of the transactions, including structuring, due diligence, assistance in the negotiation and drafting phase with counterparties and in the implementation phase.
In addition, the Firm’s professionals have gained significant expertise in mergers, demergers, spin-off and liquidation transactions, listing, takeover bids, and corporate restructuring, including through share exchanges or the transfer of businesses.
Foglia & Partners advises clients with regard to the tax implications of all major extraordinary finance transactions: issues, placements and listings of financial instruments (shares, bonds, minibonds) on regulated markets, provision of medium/long-term financing, structured finance transactions, securitisations and factoring.
In addition, the Firm also advises issuers and intermediaries involved in the placement of financial instruments in the preparation of prospectuses and Offering Circulars.
The Firm’s professionals have gained strong experience in financial taxation by assisting some of the main players in the financial sector (banks, securities and real estate fund management companies, private equity and venture capital funds) and industrial companies, in national and international structured finance and capital markets transactions.
Foglia & Partners provides advice on all issues relating to direct and indirect taxation in the international context, also dealing with the planning of cross-border reorganisation transactions of Italian and foreign multinational groups
The Firm has a consolidated track record in advance ruling procedures concerning: entry and exit values in case of transfer of residence, permanent establishments, as well as for the application of conventional and EU regimes applicable to transnational flows of dividends, interest and royalties
Foglia & Partners advises clients on all implications relating to transfer pricing regulations in the context of intra-group transactions carried out with non-resident companies, in order to ensure compliance with the arm’s length conditions of the transfer prices charged.
The Firm deals with all activities relating to the preparation, analysis and control of the set of documents necessary for the correct description and assessment of transactions with associated companies, in order to ensure compliance with the Transfer Pricing Guidelines, including: (i) the national documentation containing the information relating to intra-group transactions of the Italian entity; (ii) the Master File containing the information relating to the multinational group.
In addition, the Firm’s professionals deal with advance ruling procedures, assistance in tax audits and tax litigation, as well as out-of-court procedures.
Foglia & Partners advises clients with regard to the tax profiles of real estate transactions and, in particular, cares all tax implications relating to the transfer of real estate, building areas and real estate rights in general, both in the structuring and, in particular, cares all tax implications relating to the transfer of real estate, building areas and real estate rights in general, both in the structuring phases of the transactions, in the due diligence phase and in the negotiation phase with counterparties.
The Firm also has strong experience in the taxation of real estate funds, with particular reference to issues related to the acquisition, contribution of real estate, divestment and placement, assisting some of the main Italian and international real estate playersin acquisition, leasing, financing, divestments, creation of real estate funds under Italian law and SIIQ etc.
Foglia & Partners assists clients by advising on all issues related to VAT and other indirect taxes, such as registration tax, mortgage and cadastral taxes, estate and gift tax, as well as customs duties.
The Firm has solid experience in indirect taxation relating to international trade and e-commerce, as well as transactions in the real estate, logistics, pharmaceutical and nutraceutical, energy, gaming and collective investment undertakings sectors.
In these contexts, the Firm’s professionals have also dealt with the assessment, implementation and application of particular regimes such as, for example, the VAT Group, the VAT and Customs Warehouse, temporary admission and the transit regime, while also managing relations with the Tax and Customs Authorities during the various authorisation, ruling and tariff information procedures.
Foglia & Partners assists its clients during tax inspections by the Tax Authorities, in the pre-litigation phase, with particular reference to the preventive discussions and the preparation of defence briefs, as well as in the tax settlements. The Firm follows litigations with the utmost care at all stages: both in the initial stages of inspections and in the various in-court stages.
Tax litigation and its development in all its phases, from the first instance to the Supreme Court, are followed with ‘sartorial’ care, defining defensive strategies based on an in-depth knowledge of both the relevant substantive issues and the exquisitely procedural aspects.
Foglia & Partners advises clients with reference to all discussions with the Tax Authorities, both within the scope of ruling procedures and with reference to special regimes provided for by the law, aimed at establishing a regime of enhanced cooperation with the Tax Authorities (the so-called “cooperative compliance regime”) or at obtaining certain tax benefits granted by the domestic system.
In this context, the Firm has, inter alia, dealt with the procedures relating to admission to the so-called “cooperative compliance regime”, the definition of the methods and criteria for determining the taxable income for the purposes of the so-called “patent box” regime, and the submission of the so-called “new investments ruling”.
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 an ongoing relationship with management and a constant focus on regulatory developments, the Firm offers timely professional updates and provides clients with the most appropriate tools and solutions to best manage tax issues, including through the drafting of memoranda and opinions as well as in ruling procedures.
In this context, Foglia & Partners advises, on an ongoing basis, leading national and international companies, including listed ones.
Foglia & Partners assists private clients in estate planning, generational transitions and asset protection (e.g. family pacts; etc.).
Advising HNWIs, the Firm has gained strong experience regarding the beneficial regimes provided for individuals who transfer their residency to Italy.
Moreover, the Firm’s professionals habitually deal with the set-up of trusts, the evaluation of the taxation of structured products, and the planning of in-life generational transitions.
Foglia & Partners assists clients with regard to all corporate reorganisation, including cross-border transactions.
The Firm manages the tax profiles of all phases of the transactions, including structuring, due diligence, assistance in the negotiation and drafting phase with counterparties and in the implementation phase.
In addition, the Firm’s professionals have gained significant expertise in mergers, demergers, spin-off and liquidation transactions, listing, takeover bids, and corporate restructuring, including through share exchanges or the transfer of businesses.
Foglia & Partners advises clients with regard to the tax implications of all major extraordinary finance transactions: issues, placements and listings of financial instruments (shares, bonds, minibonds) on regulated markets, provision of medium/long-term financing, structured finance transactions, securitisations and factoring.
In addition, the Firm also advises issuers and intermediaries involved in the placement of financial instruments in the preparation of prospectuses and Offering Circulars.
The Firm’s professionals have gained strong experience in financial taxation by assisting some of the main players in the financial sector (banks, securities and real estate fund management companies, private equity and venture capital funds) and industrial companies, in national and international structured finance and capital markets transactions.
Foglia & Partners provides advice on all issues relating to direct and indirect taxation in the international context, also dealing with the planning of cross-border reorganisation transactions of Italian and foreign multinational groups
The Firm has a consolidated track record in advance ruling procedures concerning: entry and exit values in case of transfer of residence, permanent establishments, as well as for the application of conventional and EU regimes applicable to transnational flows of dividends, interest and royalties
Foglia & Partners advises clients on all implications relating to transfer pricing regulations in the context of intra-group transactions carried out with non-resident companies, in order to ensure compliance with the arm’s length conditions of the transfer prices charged.
The Firm deals with all activities relating to the preparation, analysis and control of the set of documents necessary for the correct description and assessment of transactions with associated companies, in order to ensure compliance with the Transfer Pricing Guidelines, including: (i) the national documentation containing the information relating to intra-group transactions of the Italian entity; (ii) the Master File containing the information relating to the multinational group.
In addition, the Firm’s professionals deal with advance ruling procedures, assistance in tax audits and tax litigation, as well as out-of-court procedures.
Foglia & Partners advises clients with regard to the tax profiles of real estate transactions and, in particular, cares all tax implications relating to the transfer of real estate, building areas and real estate rights in general, both in the structuring and, in particular, cares all tax implications relating to the transfer of real estate, building areas and real estate rights in general, both in the structuring phases of the transactions, in the due diligence phase and in the negotiation phase with counterparties.
The Firm also has strong experience in the taxation of real estate funds, with particular reference to issues related to the acquisition, contribution of real estate, divestment and placement, assisting some of the main Italian and international real estate playersin acquisition, leasing, financing, divestments, creation of real estate funds under Italian law and SIIQ etc.
Foglia & Partners assists clients by advising on all issues related to VAT and other indirect taxes, such as registration tax, mortgage and cadastral taxes, estate and gift tax, as well as customs duties.
The Firm has solid experience in indirect taxation relating to international trade and e-commerce, as well as transactions in the real estate, logistics, pharmaceutical and nutraceutical, energy, gaming and collective investment undertakings sectors.
In these contexts, the Firm’s professionals have also dealt with the assessment, implementation and application of particular regimes such as, for example, the VAT Group, the VAT and Customs Warehouse, temporary admission and the transit regime, while also managing relations with the Tax and Customs Authorities during the various authorisation, ruling and tariff information procedures.
Foglia & Partners assists its clients during tax inspections by the Tax Authorities, in the pre-litigation phase, with particular reference to the preventive discussions and the preparation of defence briefs, as well as in the tax settlements. The Firm follows litigations with the utmost care at all stages: both in the initial stages of inspections and in the various in-court stages.
Tax litigation and its development in all its phases, from the first instance to the Supreme Court, are followed with ‘sartorial’ care, defining defensive strategies based on an in-depth knowledge of both the relevant substantive issues and the exquisitely procedural aspects.
Foglia & Partners advises clients with reference to all discussions with the Tax Authorities, both within the scope of ruling procedures and with reference to special regimes provided for by the law, aimed at establishing a regime of enhanced cooperation with the Tax Authorities (the so-called “cooperative compliance regime”) or at obtaining certain tax benefits granted by the domestic system.
In this context, the Firm has, inter alia, dealt with the procedures relating to admission to the so-called “cooperative compliance regime”, the definition of the methods and criteria for determining the taxable income for the purposes of the so-called “patent box” regime, and the submission of the so-called “new investments ruling”.