International Taxation · Palermo
International Taxation for clients in Palermo
Sole office in Rome (Via Ancona 20): assistance remotely and at hearings before the Tax Court (Corte di Giustizia Tributaria) of First Instance in Palermo.
Transfer pricing, permanent establishments and double taxation treaties. Dedicated assistance for clients in Palermo e Sicily, 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 Palermo e Sicily. The service is structured for clients in the area: complex cases requiring specialist tax expertise.
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 Palermo
Via Filippo Cordova 76 — 90143 Palermo
The Tax Court (Corte di Giustizia Tributaria) of second instance for Sicily is based in Palermo and hears appeals from western Sicily (Palermo, Trapani, Agrigento, Caltanissetta). Catania is home to a second Tax Court (Corte di Giustizia Tributaria) of second instance serving eastern Sicily.
How the Procedure Works for Clients in Palermo
- 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 Palermo (Via Filippo Cordova 76, 90143 Palermo); hearings may take place remotely or in person, depending on the requirements of the defence.
Common Cases in Palermo e in Sicily
Tax Credit for the Single SEZ for Southern Italy
Sicily with maximum aid intensity: representation in challenges by the Italian Revenue Agency (Agenzia delle Entrate) concerning requirements, calculation, cumulation and eligible investments.
The Sicilian Region’s Own Taxes
Regional tax on public property concessions, vehicle taxes and minor taxes levied by the special-statute Region.
Agri-Food Taxation and Sicilian PDOs/PGIs
Agricultural VAT, wine excise duties, disputes concerning Sicilian PDOs/PGIs (wines, extra virgin olive oil, Pachino tomatoes, blood oranges).
Tourism and Accommodation Taxation
Accommodation establishments (hotels, B&Bs, villas, historic residences), short-term lets, tourist taxes, classification of activities.
Customs Litigation at Sicilian Ports
Valuation and customs classification adjustments for Mediterranean trade.
The Firm also assists clients in neighbouring provinces: Trapani, Agrigento, Caltanissetta, Enna, Messina.
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 Palermo
Confidential Video Consultation
Riunioni strategiche su Google Meet o Microsoft Teams.
Digital Power of Attorney
Appointment using a qualified electronic signature.
Palermo Tax Court (Corte di Giustizia Tributaria) Hearings
Partecipazione da remoto ex art. 16 D.L. 119/2018 o in presenza.
Targeted Visits
On-site visits in Palermo only when essential.
Professionals Responsible for the Service
Frequently Asked Questions
Do You Need Assistance With international taxation a Palermo?
Open a confidential case file with our team. Response within 24 hours.