International Taxation · Florence
International Taxation for clients in Florence
Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance in Florence.
Transfer pricing, permanent establishments and double taxation treaties. Dedicated assistance for clients in Florence e Tuscany, 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 Florence e Tuscany. The service is structured for clients in the area: transfer pricing for brand royalties, VAT on licences, taxation of DOC/DOCG protection consortia, expenditure-based tax assessments of HNWIs.
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 Florence
Via Cavour 56 — 50129 Florence
The Tax Court (Corte di Giustizia Tributaria) of second instance for Tuscany is based in Florence and hears appeals from all Tuscan provinces (Arezzo, Grosseto, Livorno, Lucca, Massa-Carrara, Pisa, Pistoia, Prato, Siena).
How the Procedure Works for Clients in Florence
- 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 Florence (Via Cavour 56, 50129 Florence); hearings may take place remotely or in person, depending on the requirements of the defence.
Common Cases in Florence e in Tuscany
Transfer Pricing on Royalties and Trademark Licences
Representation of luxury and fashion groups challenging adjustments by the Italian Revenue Agency (Agenzia delle Entrate) concerning intercompany royalties and trademark valuations.
Wine Sector Taxation and Protection Consortia
VAT disputes, excise duties on wine products, agricultural flat-rate tax regimes, and taxation of DOC/DOCG consortia.
Expenditure-Based Tax Assessments of Tuscan HNWIs
Representation of individuals with a high capacity to pay tax in challenges to assessments based on the availability of assets indicating wealth (villas, yachts, works of art) under art. 38 DPR 600/1973.
Taxation of Tourism and Luxury Accommodation
VAT on accommodation establishments (country house hotels, historic residences), assessments concerning receipts and the classification of activities.
Wealth Management for Tuscan Business Families
Trusts, family foundations, family business succession agreements and the intergenerational transfer of wealth and long-established family businesses.
The Firm also assists clients in neighbouring provinces: Prato, Pistoia, Arezzo, Siena, Lucca, Pisa, Livorno, Massa-Carrara, Grosseto.
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 Florence
Confidential Video Consultation
Riunioni strategiche su Google Meet o Microsoft Teams.
Digital Power of Attorney
Appointment using a qualified electronic signature.
Hearings Before the Florence Tax Court (Corte di Giustizia Tributaria)
Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.
Targeted Visits
Site visits in Florence only when essential.
Professionals Responsible for the Service
Frequently Asked Questions
Do You Need Assistance With international taxation a Florence?
Open a confidential case file with our team. Response within 24 hours.