Studio Tributario Tognolo

Managing Partner: Paolo Tognolo

Number of partners: 2

Number of lawyers: 11 (including partners)

Languages: English, Italian, French, Spanish, Portuguese

Founded in 2002, STT is an Italian firm of Tax Lawyers and economists located in Milan which provide domestic tax, international tax and company law advice and assistance to Italian and foreign multinational groups. STT has the unique ability to anticipate the potential vulnerabilities of companies’ processes, planning an efficient management in an internationally dynamic context and building the relationship with the customer based on trustworthiness. A partnership lasting in some cases over 20 years.

STT technical expertise and trustful approach permits us to efficiently manage the tax risks and solve very complex problems faced by our clients also through the dialogue with the heads of the Italian tax authorities, such as:

• Assessment on the place of effective business;
• Gentlemen Agreements (STT obtained several times the elimination of the most important matters assessed after the submission of huge technical documentation);
• Tax litigation (STT achieved so far positive sentences on 90% of the cases defended so far related to Transfer pricing – domestic corporate income tax – VAT and register tax);
• EU Arbitration Convention procedure (EU MAP) – (first application made more than 14 years ago)
• MAP (Mutual Agreement Procedures) – (first MAP signed with IRS);
• Unilateral and Bilateral APA (more than 20 procedures signed and 15 in progress);
• Patent Box (signed a relevant number of agreements with the Italian tax authorities) and New Patent Box.

STT has been assisting clients on Co-operative Tax Compliance program, together with the predisposition of a Tax Control Framework, as promoted by OECD and implemented by the Italian legislator since 2017.

STT has no connections with any auditing network. Consequently, it does not incur in any of the limitations or restrictions at present fixed by CONSOB (Italian regulatory Body), Sarbanes-Oxley American Law, or by any other foreign regulatory Bodies.

Paolo Tognolo is included in the official list of the Milan Tax Court as expert for International taxation and transfer pricing.

International Tax

• Expertise in efficient tax structuring of international groups including issues involving customs matters, transfer pricing and VAT;
• Advice on corporate tax and group tax issues, including matters specific to EU and extra-EU taxpayers, and analysis of the appropriate qualification of cross-border transactions with OECD and non OECD Countries
• Check up for BEPS compliance, including ATAD implementation and assistance on remediation.

Tax Litigation

• Legal assistance and expert advice on tax audits and investigations including extrajudicial tax disputes resolutionconcerning domestic and international corporate matters (income tax, Vat and register tax);
• Advice on alternative dispute resolution, mediation and other extra-judicial disputes;
• Assistance in the context of pre-litigation settlement procedures and Mutual Agreement procedures between the Italian and foreign tax authorities.
• Tax litigation in front of the tax Court first and second level.

Transfer pricing

• Advices to major multinational groups on transfer pricing matters, including the definition of the supply chain strategy, the selection of the transfer pricing methodology, the drafting of transfer pricing documentation;
• Predisposition of comparability analysis and functional analysis for the definition of the arms’ length margin;
• Drafting of appropriate transfer pricing documentation (Country by Country reporting, Master file and Country Specific documentation);
• Preparation of Italian, pan-European and foreign benchmarking analyzes with in-depth verification of comparable companies;

Advance Pricing Arrangements

• Predisposition of the documentation set to be filed to the Italian Competent Tax Authority for unilateral Advance Pricing Agreements
• Negotiation of unilateral Advance Pricing Agreements with the Italian Competent Tax Authority for unilateral Advance Pricing Agreements
• Predisposition of the documentation set to be filed to the Italian Competent Tax Authority and the foreign Competent Tax Authority for bilateral Advance Pricing Agreements
• Assistance negotiation of bilateral Advance Pricing Agreements with the relevant Competent Tax Authority, both in Italy and abroad.

Patent Box regime

• Predisposition of the documentation set to be filed to the Italian Tax Authority;
• Negotiation with the Italian tax authority team to define the methodology and the quantification of the tax relief;
• Assistance to the taxpayer in the implementation of the agreement signed for the subsequent tax periods;
• Communication to the authorities in case of changes in the business;
• Renewal of the relief.

Cooperative compliance programs (and ICAP)

• Assistance in the definition of the tax control framework and the related procedures
• Assistance and advice in the relationship with the Italian tax authorities’ competent team.

Tax Risk Management & Tax Control Framework

• Design and implementation of the internal control system for tax risk management (so-called Tax Control Framework);
• Tax risk assessment and control activities identification;
• Evaluation of the design and effectiveness of control activities (test of design and operating effectiveness);
• External audit on the adequacy of the Tax Control Framework.

Contact Name: Paolo Tognolo – Francesco Spurio

Email:[email protected] – [email protected]

ITALY

STUDIO TRIBUTARIOTOGNOLO

20121 Milan - Via P. Paleocapa 1

Phone Number:+39.02.860988

Fax:+39.02.80509635

Email: [email protected]