Corporate Tax · Naples

    Corporate Tax for clients in Naples

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

    Tax advice on extraordinary corporate transactions and corporate restructuring. Dedicated assistance for clients in Naples e Campania, 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 Naples e Campania. The service is structured for clients in the area: business disputes involving SMEs (restaurants, accommodation, construction, agri-food), a substantial volume of litigation concerning enforced collection, local taxes (municipal property tax (IMU), TARI) and assessments relating to tourism and property activities.

    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 in Naples

    Via dei Tribunali 224 (Castel Capuano) — 80138 Naples

    Historic premises in the Castel Capuano complex. One of the Italian courts with the highest volumes of pending litigation. The Tax Court (Corte di Giustizia Tributaria) of second instance for Campania is based in the same city.

    How the Procedure Works for Clients in Naples

    1. 1

      Corporate Structure Analysis

      Reviewing the current structure, intra-group relationships and the transaction's business objectives.

    2. 2

      Assessment of Alternatives

      Comparing the possible legal routes and quantifying the tax burden of each.

    3. 3

      Documentary Safeguards

      Establishing valid non-tax reasons and preparing supporting documentation, including for a potential anti-abuse tax ruling request (interpello).

    4. 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 in Naples (Via dei Tribunali 224 (Castel Capuano), 80138 Naples); hearings may take place remotely or in person, depending on the requirements of the defence.

    Common Cases in Naples e in Campania

    Analytical and Presumptive Tax Assessments of SMEs

    Defence against sector studies, ISA, assessments based on the redditometro and the availability of assets indicating ability to pay tax.

    Enforced Collection Litigation

    Challenges to tax payment notices (cartella), demands for payment, administrative vehicle seizures (fermo amministrativo) and tax mortgages (ipoteca) imposed by the Italian Tax Collection Agency (ADER).

    IVA nei settori ricettivo e ristorazione

    Contestazioni su aliquote ridotte, regime forfettario, fatturazione elettronica e corrispettivi telematici.

    Local Taxes and Municipal Property Tax (IMU)/TARI Litigation

    Appeals against tax assessments issued by municipalities in the province of Naples concerning properties, accommodation businesses and waste generation.

    Construction, Public Procurement and Sector-Specific Taxation

    Defence against claims concerning VAT, withholding taxes, social security contributions and joint and several liability in construction contracts.

    The Firm also assists clients in neighbouring provinces: Caserta, Salerno, Avellino, Benevento.

    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 Naples

    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 Naples

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

    Targeted Visits

    Visits to Naples only when essential.

    Professionals Responsible for the Service

    Frequently Asked Questions

    Do You Need Assistance With corporate tax a Naples?

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

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