Facchini Rossi Michelutti Studio Legale Tributario

Partners: Francesco Facchini, Luca Rossi, Riccardo Michelutti, Marina Ampolilla, Francesco Capitta, Giancarlo Lapecorella, Stefano Massarotto, Andrea Prampolini

Number of partners: 8

Number of lawyers and chartered accountants: 30

Languages: English, Italian

Firm Overview:

Facchini Rossi Michelutti Studio Legale Tributario (“FRM”), is an Italian based boutique tax law firm focused in delivering innovative, comprehensive, and tax-efficient solutions on all sorts of transactions. FRM works hand in hand with its clients, which mainly consist of large corporations, banks, private equity and real estate funds and high net-worth individuals, in order to develop and implement new solutions that are tailor-made for the different needs. Since its foundation, FRM has achieved widespread recognition as a point of reference in the field of taxation. The firm has been established in 1998 by its founding partners, Francesco Facchini and Luca Rossi specialising in particular in M&A and LBO transactions. In 2019 Riccardo Michelutti, formerly senior partner of a leading international tax law firm, joined FRM as a name partner. Nowadays the firm is made of a team of more than thirty professionals, lawyers and chartered accountants, working in the office of Milan.

Main Areas of Practice:

■ Tax Advice

■ Tax on M&A

■ Tax Litigation

FRM provides a full range of services which include tax consultancy services, international taxation, transfer pricing, assistance in tax litigation as well as pre-litigation phases and in ruling procedures with the Italian tax authorities.

Corporate Tax:

In the field of corporate taxation, FRM provides a comprehensive range of consultancy services to meet the needs of all sorts of companies and transactions (such as business restructurings, M&A deals, tax optimisation schemes, securitisations), including any related cross-border tax implications. In particular, FRM provides consultancy services for multinationals, banking and financial institutions. Specific expertise has been developed with reference to the taxation of sophisticated financial products and to the tax aspects of the application of the International accounting standards IAS/IFRS.

Management Incentive Plans:

The firm provides consultancy services in the field of management incentive plans/carried interest schemes for employees/directors of corporations and investment funds.

International Taxation:

The firm provides advice on any type of international tax matters, including the application of tax treaties, international tax planning for multinational groups, international tax rulings and transfer pricing issues. FRM’s services also cover issues relating to State Aid and the application of fundamental freedoms guaranteed by the Treaty on the Functioning of the European Union.

Taxation of Individual and Estate Planning:

The firm works extensively with high net worth individuals and families with respect to transfers of residence (inbound and outbound) and generational tax planning. The professionals have a specific expertise in all tax aspects relating to the settlement and unwinding of trusts, financial and insurance products, and ownership of ships and aircrafts.

Private Equity Funds:

Since its foundation FRM has gained an extensive experience in dealings with private equity funds and is now a leading tax firm as far as LBO transactions are concerned. In particular, FRM assists both foreign and domestic private equity funds and has a strong reputation and knowledge on all tax issues connected to the structuring of complex financing transactions. FRM provides also backup activities in the context of LBO transactions, including activities of tax due diligence.

Tax Litigation:

The firm provides assistance at all stages of tax litigation and pre-litigation. FRM draws up defenses arising out of tax audits and represents companies and individuals before tax courts, the Italian Supreme Court of Cassation The firm gained particular experience in the management of the pre-litigation phases with the Italian tax authorities in order to achieve settlement of complex tax matters. The experience of the firm also covers dealing with criminal tax matters, arising in the context of tax audits and tax assessments, in collaboration with well-reputed criminal lawyers.