International Taxation · Naples
International Taxation 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.
Transfer pricing, permanent establishments and double taxation treaties. 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 international taxation 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 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 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
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 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
- —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 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 international taxation a Naples?
Open a confidential case file with our team. Response within 24 hours.