Corporate Tax · Milan
Corporate Tax for clients in Milan
Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance of Milan.
Tax advice on extraordinary corporate transactions and corporate restructuring. Dedicated assistance for clients in Milan e Lombardy, 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 corporate tax to businesses and taxpayers in Milan e Lombardy. The service is structured for clients in the area: litigation before the Tax Court (Corte di Giustizia Tributaria) in Lombardy is dominated by high-value business disputes (intra-Community VAT, transfer pricing, fictitious foreign tax residence, R&D tax credits, abuse of law in extraordinary corporate transactions).
What Is corporate tax and When Is It Needed
Corporate tax advice concerns routine business taxation and the taxation of extraordinary transactions: calculating corporate income tax (IRES) and IRAP, cost deductibility, extraordinary transactions (mergers, demergers, contributions of assets, business transfers), group reorganisations, tax consolidation and assessing the risk of abuse of law under art. 10-bis dello Statuto del contribuente.
Business Taxation
We assist businesses and corporate groups in managing tax matters in their ordinary activities and extraordinary transactions, ensuring the correct application of tax rules and the optimisation of their tax burden.
Areas of Expertise
- Direct Taxes: Advice on corporate income tax (IRES), IRAP and the calculation of business income.
- Operazioni Straordinarie: Tax analysis of mergers, demergers, capital contributions and changes of legal form.
- Tax Consolidation: Management of group taxation and optimisation of corporate structures.
- Pareri Pro Veritate: Preparation of technical opinions on legal issues that are disputed or whose application is uncertain.
Tax Court (Corte di Giustizia Tributaria) of First Instance of Milan
Via Conservatorio 22 — 20122 Milan
The Tax Court (Corte di Giustizia Tributaria) in Milan has one of Italy's heaviest corporate litigation caseloads and some of the shortest case resolution times in the country. The Tax Court (Corte di Giustizia Tributaria) of second instance for Lombardy is based in the same city.
How the Procedure Works for Clients in Milan
- 1
Corporate Structure Analysis
Reviewing the current structure, intra-group relationships and the transaction's business objectives.
- 2
Assessment of Alternatives
Comparing the possible legal routes and quantifying the tax burden of each.
- 3
Documentary Safeguards
Establishing valid non-tax reasons and preparing supporting documentation, including for a potential anti-abuse tax ruling request (interpello).
- 4
Implementation Support
Support in finalising the legal instruments and subsequently managing relations with the tax authorities.
Documents are filed electronically with the Tax Court (Corte di Giustizia Tributaria) of First Instance of Milan (Via Conservatorio 22, 20122 Milan); hearings may take place remotely or in person, depending on the requirements of the defence.
Common Cases in Milan e in Lombardy
IVA intracomunitaria e frodi carosello
Defence against allegations of fictitious transactions, failure to apply the reverse charge mechanism and breaches of the principle of VAT neutrality.
Transfer Pricing and Intra-Group Prices
Transfer pricing adjustments under art. 110 TUIR, OECD guidelines, defence of documentation and APAs.
Fictitious Foreign Residence and Corporate Tax Residence
Defence against claims that formally foreign companies are tax-resident in Italy under art. 73 TUIR.
Crediti d'imposta R&S e Industria 4.0
Challenges by the Italian Revenue Agency (Agenzia delle Entrate) concerning non-existent tax credits or credits to which the taxpayer is not entitled, classification of research activities, sworn technical expert reports.
Abuse of Law in Extraordinary Corporate Transactions
Defence of valid non-tax commercial reasons for mergers, demergers and contributions challenged under art. 10-bis Statuto del Contribuente.
The Firm also assists clients in neighbouring provinces: Monza-Brianza, Pavia, Varese, Como, Lecco, Bergamo, Brescia, Lodi.
Documents to Gather and Timeframes
- —Up-to-date company register extract and articles of association
- —Financial statements for the last three financial years
- —Income tax and IRAP returns
- —Valuation reports and relevant contracts
- —Resolutions and Plans Relating to the Transaction
Extraordinary corporate transactions take varying amounts of time depending on the corporate law requirements; an anti-abuse tax ruling request (interpello) receives a response within the time limits laid down in the Taxpayer's Charter, subject to suspension for fact-finding purposes.
For an assessment of your position, you can or consult the profile of the Firm's tax lawyers.
How We Handle corporate tax for Clients in Milan
Confidential Video Consultation
Riunioni strategiche su Google Meet o Microsoft Teams.
Digital Power of Attorney
Appointment using a qualified electronic signature.
Hearings at the Milan Tax Court (Corte di Giustizia Tributaria)
Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.
Targeted Visits
Site visits in Milan only when essential.
Professionals Responsible for the Service
Frequently Asked Questions
Do You Need Assistance With corporate tax a Milan?
Open a confidential case file with our team. Response within 24 hours.