International Taxation · Bologna
International Taxation for clients in Bologna
Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance in Bologna.
Transfer pricing, permanent establishments and double taxation treaties. Dedicated assistance for clients in Bologna e Emilia-Romagna, 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 Bologna e Emilia-Romagna. The service is structured for clients in the area: Motor Valley, packaging, biomedical industries, precision engineering, agri-food and cooperatives.
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 Bologna
Via Marco Polo 60 — 40131 Bologna
The Tax Court (Corte di Giustizia Tributaria) of second instance for Emilia-Romagna is based in Bologna and hears appeals from all provinces of Emilia-Romagna (Modena, Reggio Emilia, Parma, Piacenza, Ferrara, Ravenna, Forlì-Cesena, Rimini).
How the Procedure Works for Clients in Bologna
- 1
Mapping Flows and Entities
Reconstructing shareholdings, intra-group contracts and relevant cross-border flows.
- 2
Treaty Analysis
Reviewing residence, tie-breaker rules and the treaty treatment applicable to each flow.
- 3
Documentation and Safeguards
Preparing the Master File and Local File to qualify for transfer pricing penalty protection.
- 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 Bologna (Via Marco Polo 60, 40131 Bologna); hearings may take place remotely or in person, depending on the requirements of the defence.
Common Cases in Bologna e in Emilia-Romagna
IVA intracomunitaria e cessioni UE
Defence against allegations of non-existent transactions, evidence of intra-EU supplies, and correct application of VAT exemption regimes.
Crediti d'imposta R&S e Industria 4.0
Disputes over technology tax credits challenged as non-existent, sworn expert reports and classification of activities.
Transfer Pricing in Motor Valley and Packaging Groups
Defence of transfer pricing documentation, master files and country files for groups with foreign subsidiaries.
Taxation of Cooperative Companies
Disputes concerning the application of preferential regimes under L. 904/1977, indivisible reserves and predominantly mutual status.
Agri-Food Taxation and PDO/PGI
IVA, IRAP e tributi indiretti nelle filiere produttive emiliane (Parmigiano, prosciutto, aceto balsamico, vini).
The Firm also assists clients in neighbouring provinces: Modena, Reggio Emilia, Parma, Ferrara, Ravenna, Forlì-Cesena, Rimini, Piacenza.
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 Bologna
Confidential Video Consultation
Riunioni strategiche su Google Meet o Microsoft Teams.
Digital Power of Attorney
Appointment using a qualified electronic signature.
Hearings Before the Tax Court (Corte di Giustizia Tributaria) of Bologna
Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.
Targeted Visits
Site visits in Bologna only when essential.
Professionals Responsible for the Service
Frequently Asked Questions
Do You Need Assistance With international taxation a Bologna?
Open a confidential case file with our team. Response within 24 hours.