Tax Due Diligence · Naples
Tax Due Diligence 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 analysis for M&A transactions and investments. 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 tax due diligence 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 tax due diligence and When Is It Needed
Tax due diligence is the analysis of the tax risks of a company or business division in preparation for an acquisition, investment or reorganisation. It covers direct taxes, VAT, indirect taxes, pending litigation, tax relief claimed and outstanding tax liabilities, with quantification of contingent liabilities and guidance on contractual warranty clauses.
Audit and Risk Analysis
The Due Diligence service aims to identify potential hidden tax risks ("tax risks") and untapped opportunities within target companies or asset portfolios.
Stages of the Work
- Tax Check-up: Checking the correct application of direct and indirect taxes in financial years still open to tax audit.
- Analisi M&A: Support for investors and funds in the preliminary stages of business acquisitions to determine the true value of the deal.
- Employment Compliance: Checking tax and social security deductions for employees and other workers.
- Reportistica: Preparation of detailed reports identifying potential liabilities and mitigation strategies.
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
Defining the Scope
Identifying the tax years, taxes and companies to be analysed, taking account of the statutory time limits for tax assessments.
- 2
Data Room and Document Requests
Sending the request list and analysing management's responses.
- 3
Risk Analysis
Quantifying contingent liabilities for taxes, penalties and interest, classified by likelihood.
- 4
Report and Clauses
Delivery of the report with practical guidance on price adjustments, representations & warranties and indemnities.
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
- —Financial statements and tax returns for years still open to assessment
- —VAT Registers and Calculations
- —Pending Litigation and Documents Served
- —Intra-group Contracts and Transfer Pricing Documentation
- —Documentazione su crediti d'imposta e agevolazioni fruite
Due diligence on a medium-sized target generally takes two to four weeks from the date the complete data room becomes available, with interim reports for transactions on tight timetables.
For an assessment of your position, you can or consult the profile of the Firm's tax lawyers.
How We Handle tax due diligence 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 tax due diligence a Naples?
Open a confidential case file with our team. Response within 24 hours.