Handling Competent Authority Cases

If you are faced with the prospect of international double taxation as a result of the fact that a country is imposing a tax in a manner that is inconsistent with an income tax treaty, you can resort to the competent authority process to avoid or at least minimize such international double taxation and obtain other forms of assistance in the international context. The competent authority process is designed to assure the proper application of a tax treaty to the benefit of taxpayer and is crucial for the proper working of the tax treaties system. Unfortunately, many taxpayers are not familiar with the competent authority mechanism and fail to obtain all the benefits it can provide. We can assist you to avail of the competent authority process to its full extent. Our services in this area include:

• studying the best strategy for obtaining the requested relief;
• preparing written Competent Authority request for relief tailored to your situation and in accordance with the formal and informal requirements of the Competent Authority of the relevant country;
• meeting with the appropriate Italian and/or foreign government personnel to promote timely and favorable action on the Competent Authority request;
• drafting proposed Competent Authority ruling or agreement.