Italian International Tax Practice

Our sophisticated Italian international tax practice is specifically dedicated
to assisting foreign individual and business clients with the full range of services on all Italian international tax matters
In Italy we assist foreign individual taxpayers to properly handle their Italian international tax issues concerning Italian tax residency and pre-immigration tax planning, Italian international tax return preparation and filing, Italian international tax audits and Italian tax court litigation, taxation of Italian source income and Italian withholding tax issues.

We operate an extremely sophisticated Italian international tax practice for foreign individuals, spanning from Italian tax residency and pre-immigration planning, to Italian international tax filing, reporting and compliance, and Italian international tax audits and tax court litigation
We also assist foreign companies doing business in Italy with Italian international tax advice concerning permanent establishment issues, taxation of foreign-owned or controlled Italian subsidiaries, transfer pricing, international tax rulings, Italian withholding taxes on outbound dividends, interest and royalties, EU tax directives issues, Italian tax treaties, Italian anti abuse provisions, internaitonal corporate tax audits and tax court litigation.

Our Italian international tax practice for foreign investors and business clients regularly advice foreign-owned entities and companies on Italian international investment and business tax matters spanning from Italian withholding taxes to Italian transfer pricing, Italian permanent establishment and subsidiaries international tax planning, and Italian international tax rulings. 
We assist foreign families and individuals with sophisticated advice on Italian trust and estate matters, Italian taxation of foreign trusts with Italian assets, settlors or beneficiaries, Italian estate taxation of foreign estates with Italian assets or beneficiaries, Italian internaitonal reporting and compliance matters.

We specifically provide foreign families with Italian international trust and estate tax planning and advice
We provide advice on all issues arising under Italy's income tax treaties, assistance for the purpose of obtaining international tax rulings, support in pre-audit negotiations with the Italian tax agencies, strategic advice in international tax audits and litigation in front of Italian courts. Our services are exclusively provided to U.S. and foreign clients on international tax matters, thereby benefiting the clients with specific focus and dedicated knowledge and expertise.

Areas of Practice

Italian Tax Residency Planning, Assistance and Advice For Foreign Individuals
Foreign clients who own houses in Italy, travel to and spend time there regularly, alone or with their family, for business or pleasure, need to be aware of Italian tax rules on tax residency for individuals taxpayers. Italy assigns tax residency to individuals based on one of three alternative tests: registration on the Italian register of resident individuals, regular place of abode (true home) and domicile (main center of interests). The sole fact of being registered on the Italian list of resident individuals for more than 183 days in any given year triggers Italian tax residency under Italian internal tax laws. Place of abode and domicile depend heavily on the facts and circumstances of each particular case, such as the time spent in Italy and the nature, extent and number of ties or connections with the country at the personal, family, economic and business level.

Spending time in Italy, owning houses or investments there, and establishing other connections with Italy on personal, family, economic or business level may expose to Italian tax residency. Italian tax residency is determined pursuant to facts and circumstances tests revolving around the taxpayer's permanent home coupled with a subjective intention to remain there on a permanent basis, and his or her personal, family, economic and business contacts with Italy.
Tax residency requires careful planning and specific advice. Very often, tax audits are initiated on the tax status of foreign citizens and residents in Italy as a result of or in connection with the purchase or ownership of Italian houses or other investment assets, opening of or holding Italian bank accounts, or the transfer of money from the U.S. into Italy (that is automatically registered in the Italian tax agency's data base).

Italian international tax audits on U.S. and foreign citizens and residents are often initiated in connection with the purchase or ownership of Italian houses, traveling to Italy and showing on the Italian list of resident individuals.      
Individual international tax audits in Italy require careful advice, to make sure that the case is closed upfront and to avoid the need to go to the tax court to challenge a tax assessment. Very often, foreign tax legal, banking and tax documents must be used and properly explained to Italian tax authorities, and risks of misunderstanding and unintented outcome in the tax investigation are extremely high and dangerous. A clear understanding of foreign tax and legal information to be used in the Italian audits is crucial for that purpose.

Italian tax audits on cross border tax matters for individual taxpayers require specific expertise, proper use and presentation of foreign legal, financial and tax information, and thourgh discussion of client's position with the Italian tax aurhority.          
Litigation of an international tax case before the Italian tax courts is extremely challenging, due to strict procedural rules, limitation on appeal rights, and the tax court's attitude generally inclined to rule in favor of tax agencies.

We assist U.S. and foreign clients with tax advice on Italian tax residency, strategic assistance in Italian international tax audits, and aggressive representation in tax court cases.
For U.S. and foreign clients whose Italian tax residency is established, we provide assistance on Italian income tax returns and international tax reporting and disclosure of non Italian assets on Italian tax return's section RW.

We assist U.S. and foreign clients on Italian international tax reporting on their U.S. and non Italian assets on Italian income tax return's Section RW
In this area, we provide the following services:

  • Italian tax residency preliminary study, analysis and advice,
  • Italian pre-immigration tax planning,
  • Representation and assistance in international tax audits before Italian tax agencies,
  • Representation and assistance in international tax cases and controversies before Italian tax courts.