Tax Debt Restructuring · Milan
Tax Debt Restructuring 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 settlements and insolvency proceedings. 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 tax debt restructuring 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 tax debt restructuring and When Is It Needed
Tax debt restructuring involves managing liabilities to the Italian Revenue Agency (Agenzia delle Entrate) and the Italian Tax Collection Agency (ADER): instalment plans, tax settlements within preventive composition proceedings and restructuring agreements (artt. 63 e 88 del Codice della crisi, D.Lgs. 14/2019), negotiated settlements and over-indebtedness procedures. The aim is to ensure that the plan is sustainable and the business can continue operating.
Business Insolvency Management
We support businesses in financial difficulty through the tools provided by the Business Insolvency Code, with a specific focus on renegotiating tax debt.
Tools Used
- Tax Settlement: Negotiations with the Italian Revenue Agency (Agenzia delle Entrate) to reduce tax debt and extend payment terms (Art. 182-ter L.F. / Codice della Crisi).
- Restructuring Agreements: Assistance in drafting court-approved recovery plans.
- Rottamazione e Definizione Agevolata: Assessment of the opportunities offered by "tax truces" to reduce penalties and interest.
- Sovraindebitamento: Procedures for managing the financial distress of persons and entities not subject to bankruptcy proceedings and of professionals.
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
Debt Snapshot
Extract from the collection register and detailed breakdown of taxes, penalties, interest and collection fees, with checks on limitation periods.
- 2
Choice of Instrument
Comparison of ordinary or extraordinary instalment plans, negotiated settlements, restructuring agreements and composition proceedings.
- 3
Preparing the Proposal
Preparation of the plan and the report on its advantages over judicial liquidation.
- 4
Negotiations and Court Approval
Negotiations with the relevant offices, filing of the tax settlement proposal and management of the court approval stage.
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 Extract from the Collection Register
- —Tax Payment Notices (cartella), Demands for Payment and Administrative Vehicle Seizure (fermo amministrativo) or Tax Mortgage (ipoteca) Orders
- —Bilanci e situazione economico-patrimoniale aggiornata
- —Business and Financial Plan
- —List of Creditors and Existing Security
Ordinary instalment plans are processed promptly by the collection agent; insolvency resolution procedures follow the time limits set by the Insolvency Code, with their duration depending on the complexity of the plan and the number of creditors.
For an assessment of your position, you can or consult the profile of the Firm's tax lawyers.
How We Handle tax debt restructuring 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 tax debt restructuring a Milan?
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