Foglia & Partners

Senior Partners: Giuliano Foglia
Number of partners: 4
Number of lawyers: 16
Languages: English, Italian, French, German

Firm Overview:
Foglia & Partners is an independent Italian law firm specialising in tax law. It was established in 2016 by professionals with many years of experience from the will to create a boutique of excellence to advise clients in all the main areas of national and international tax law.

Thanks to the expertise, experience and strong client-focused approach of the associates, the firm is recognised as a reference point in corporate reorganisations, taxation of corporations and of individuals, in real estate tax, taxation of financial instruments and of estates, transfer pricing and tax litigation.

The firm consists of a team in steady growth composed by professionals with high professional and human standing, with great experience in relevant operations and great enthusiasm and commitment to work together and guide clients through the most complex strategic and management decisions. Most of the firm members participate in advisory bodies and study groups, are frequent speakers at congresses and contribute to publications and to the most prestigious Italian and foreign tax journals.

Key Clients: The clients of Foglia & Partners are represented mainly by large national and international corporations and high net worth individuals. The clients operate in several different industries such as banking, manufacturing, fashion and luxury goods, pharmaceutical, energy, gaming, real estate, consulting, venture capital and private equity markets. The firm has also developed significant expertise in tax consultancy to private clients in structuring their wealth.

Main Areas of Practice:  

Corporate & Group Taxation: The firm deals with all aspects of corporate taxation, from the issuance of opinions on specific tax matters to advisory on the determination of the tax burden and on the revision of the Income Tax Return. The constant attention to regulatory developments allows the firm to offer a professional and prompt update and to provide customers with the tools and the most appropriate solutions to best manage tax issues.

M&A & Corporate Restructuring: The firm provides specialised consultancy on all tax issues arising from extraordinary corporate transactions (mergers, divisions, corporate relocations, transfers of shares, venture capital and private equity, corporate restructuring). Over the last years, the firm’s professionals played advisory roles in the most important transactions in the market, both national and international, with respect to corporate reorganisations, M&A and private equity acquisition. In this field, the advisory activities include the due diligence analysis, the analysis on the tax consequences of the different available options, assistance in the negotiation phase with the counterparts and the implementation phase.

Taxation of Financial Instruments: The firm has specific expertise in the tax regime of all the major corporate finance transactions: issues, placements and financial instruments listing (shares, bonds, mini-bonds) in regulated markets, medium and long-term funding, structured finance operations, securitisations, factoring. Moreover, the firm advises issuers and intermediaries which intervene in the financial instruments placement and in the preparation of prospectuses and of Offering Circulars.

Real Estate Taxation: The firm is highly specialised in real estate tax and, in particular, in all tax issues related to transfers of real properties. The professional activity of the firm includes all phases of real estate transactions, from the structuring phase of purchase and transfer of properties and of building areas, to the negotiation phase with counterparts.

Tax Planning for High Net Worth Individuals: The law firm provides advisory on the main aspects of individuals’ taxation. In this context, the assistance also covers tax issues related to ownership, management, protection and transfer of important estates. The firm has specific expertise on trust, insurance products and inheritance matters. The firm handles complex tax litigation and pre-litigation settlements concerning high net worth individuals, including litigation and settlements involving financial products, life insurance policies, foundations, trusts and unreported foreign assets.

International Taxation & Transfer Pricing: The firm provides consultancy in respect of all the matters which pertain to direct and indirect taxation of cross-border transactions. In detail, the activity of the firm covers the tax regime of foreign sourced income earned by Italian resident persons and of Italian sourced income earned by non-Italian resident persons, the analysis of the tax ramifications and the planning of cross-border reorganisations of Italian and foreign multinational groups, the assistance in setting the correct transfer pricing of intra-group transactions and in arranging proper transfer pricing documentation. The firm advises its clients in the context of advance ruling procedures with regards to: transfer pricing matters; cross-border reorganisations; transfers or tax residency; requirements as to the existence of an Italian permanent establishment; quantification of income of Italian permanent establishments; tax treaty regime applicable to cross-border flows of dividends, interest and royalties.

Ruling Procedures & Tax Litigation: The firm evaluates the advance ruling procedure as a primary tool to obtain certainty on a preventive basis and to avoid judicial litigations in front of tax courts. The firm assists its clients in the course of tax audits carried out by the Revenue Agency and by the Italian Tax Police and in particular it represents the clients in the administrative phase of opposition and of settlement with the Italian tax authorities. The professionals of the firm are also highly specialised in litigation in all levels of courts in front of both national and international jurisdictional authorities.