International Taxation · Bari

    International Taxation for clients in Bari

    Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance in Bari.

    Transfer pricing, permanent establishments and double taxation treaties. Dedicated assistance for clients in Bari e Apulia, managed entirely through the electronic tax court filing system (PTT) from the Firm's office in Rome.

    In Brief

    The Firm Marzo Associati offers specialist assistance in international taxation to businesses and taxpayers in Bari e Apulia. The service is structured for clients in the area: ZES Adriatica unica, credito d'imposta investimenti SUD, bonus assunzioni, agevolazioni 4.

    What Is international taxation and When Is It Needed

    International taxation concerns the taxation of income and structures with cross-border elements: the tax residence of individuals and companies, permanent establishments, transfer pricing (art. 110, comma 7, TUIR), withholding taxes on dividends, interest and royalties, the application of double taxation treaties and EU directives, and the tax reporting obligations under Schedule RW.

    Advice on Overseas Matters

    We support resident and non-resident clients in navigating the complexities of cross-border taxation, preventing double taxation risks and ensuring global compliance.

    Topics Covered

    • Transfer Pricing: Analysis and preparation of documentation to substantiate intra-group transfer prices.
    • Stabile Organizzazione: Assessment of risks associated with the physical or digital presence of foreign businesses in Italy (and vice versa).
    • Expatriates: Tax management for workers posted abroad or moving to Italy under the Italian inbound workers' tax regime (impatriati) (tax relief regimes).
    • Voluntary Disclosure: Assistance with procedures to regularise capital held abroad.

    Tax Court (Corte di Giustizia Tributaria) of First Instance in Bari

    Via Melo da Bari 247 — 70121 Bari

    The Tax Court (Corte di Giustizia Tributaria) of second instance for Apulia is based in Bari and hears appeals from all the provinces of Apulia (BAT, Brindisi, Foggia, Lecce, Taranto).

    How the Procedure Works for Clients in Bari

    1. 1

      Mapping Flows and Entities

      Reconstructing shareholdings, intra-group contracts and relevant cross-border flows.

    2. 2

      Treaty Analysis

      Reviewing residence, tie-breaker rules and the treaty treatment applicable to each flow.

    3. 3

      Documentation and Safeguards

      Preparing the Master File and Local File to qualify for transfer pricing penalty protection.

    4. 4

      Managing Tax Disputes

      Defence during tax audits and in court concerning fictitious foreign corporate residence, undisclosed permanent establishments and transfer pricing adjustments; assessing a tax ruling request (interpello) or mutual agreement procedure (MAP).

    Documents are filed electronically with the Tax Court (Corte di Giustizia Tributaria) of First Instance in Bari (Via Melo da Bari 247, 70121 Bari); hearings may take place remotely or in person, depending on the requirements of the defence.

    Common Cases in Bari e in Apulia

    Tax Credit for the Single SEZ for Southern Italy

    Representation in challenges by the Italian Revenue Agency (Agenzia delle Entrate) concerning eligibility requirements, investment classification, calculation of aid intensity and cumulation with other incentives.

    Bonus investimenti SUD e agevolazioni 4.0 maggiorate

    Litigation concerning the Southern Italy investment tax credit (L. 208/2015) and enhanced Industry 4.0 incentives specific to the regions of SOUTHERN ITALY.

    Agri-Food and Farm Tourism Taxation

    Agricultural VAT, the flat-rate tax regime, farm tourism and disputes over the classification of ancillary agricultural activities.

    Customs Litigation at the Port of Bari

    Valuation adjustments, customs classification, preferential origin and challenges concerning imports from the Adriatic and the Balkans.

    Tourism Taxation in Apulia

    Tourist accommodation (masserie, B&Bs, hotels), tourist taxes, VAT on tourism services and short-term lets.

    The Firm also assists clients in neighbouring provinces: BAT (Barletta-Andria-Trani), Brindisi, Foggia, Lecce, Taranto.

    Documents to Gather and Timeframes

    • —Corporate organisation chart and ownership chain
    • —Intra-group contracts and service agreements
    • —Financial statements and tax returns of the entities involved
    • —Any transfer pricing documentation already prepared
    • —Tax residence certificates and evidence of economic substance abroad

    A preliminary analysis of a cross-border structure generally takes a few weeks, depending on the documentation available. Disputes concerning residence and transfer pricing are subject to the ordinary assessment time limits, extended in the cases provided for by law.

    For an assessment of your position, you can or consult the profile of the Firm's tax lawyers.

    How We Handle international taxation for Clients in Bari

    Confidential Video Consultation

    Riunioni strategiche su Google Meet o Microsoft Teams.

    Digital Power of Attorney

    Appointment using a qualified electronic signature.

    Hearings at the Tax Court (Corte di Giustizia Tributaria) of Bari

    Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.

    Targeted Visits

    Site visits in Bari only where essential.

    Professionals Responsible for the Service

    Frequently Asked Questions

    Do You Need Assistance With international taxation a Bari?

    Open a confidential case file with our team. Response within 24 hours.

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