Ciani Partners | Digital Commerce

Digital Commerce Tax

Tax and legal services for digital businesses

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Ciani Partners | Avvocati Tributaristi Milano

Digital Commerce Tax

Digital Commerce Tax

Taxation of e‑commerce, digital platforms and online business models in domestic and international contexts

Ciani Partners assists companies and digital commerce operators in managing taxation related to e‑commerce, online platforms, marketplaces and digital business models. The firm combines expertise in tax law, VAT, EU law and digital services regulation to support clients in correctly qualifying their activities, handling compliance obligations and preventing tax disputes. Our aim is to design tax frameworks that are consistent with domestic and supranational rules, reducing the risk of double taxation, VAT mismatches and issues arising from digital presence across multiple jurisdictions.

Service Overview

Ciani Partners provides specialised advisory services on the taxation of digital commerce, supporting companies operating through websites, platforms, apps and marketplaces in correctly handling direct and indirect taxes. The firm assists in qualifying business models, structuring contractual flows and assessing the tax effects of different online distribution and sales methods.

Our services target operators managing B2C and B2B e‑commerce, intermediation platforms, digital services and hybrid online/offline models. Ciani Partners helps identify tax risk areas related to digital presence in multiple countries, cross‑border sales and the interplay between domestic law, EU rules and international provisions.

Direct Taxation and Digital Permanent Establishment

The growing importance of digital business models requires careful assessment of direct tax aspects, including the possible existence of digital permanent establishments or significant tax presence in foreign jurisdictions. Ciani Partners assists companies in mapping activities performed, income flows and functions allocated across entities and countries.

  • Analysis of the tax qualification of income derived from e‑commerce, digital services, software licensing and other online activities.
  • Assessment of whether a digital permanent establishment or significant tax presence exists in other States, based on OECD practice, double tax treaties and domestic rules.
  • Design of income allocation policies among group companies, considering arm’s length principles and rules on tax base and profit allocation.
  • Review of double taxation issues and identification of treaty‑based or procedural tools to mitigate them.

VAT, E‑Commerce and Special Regimes

Indirect taxation of digital models is characterised by complex VAT and e‑commerce rules, with specific regimes for digital services, distance sales, marketplaces and special schemes. Ciani Partners supports companies in correctly handling VAT obligations, choosing appropriate regimes and managing risks associated with misallocation or territoriality errors.

  • Advice on the qualification of direct and indirect e‑commerce transactions, including analysis of territoriality rules and VAT application methods.
  • Assistance with cross‑border B2C and B2B sales, including OSS/IOSS schemes and other simplification tools under EU law.
  • Support for marketplaces and intermediation platforms in correctly applying VAT rules to transactions where the intermediary may be treated as supplier for VAT purposes.
  • Review of filing obligations, invoicing procedures and periodic communications to reduce the risk of challenges and penalties.

Compliance, Tax Audits and Operational Strategies

Tax management of digital commerce requires robust compliance safeguards capable of linking IT systems, sales platforms and tax obligations. Ciani Partners assists companies in designing processes and controls that reduce the risk of errors, and in managing tax audits and disputes related to online activities.

  • Design of tax compliance processes integrated with e‑commerce platforms, ERP systems and payment solutions.
  • Assistance during tax audits concerning digital activities, including analysis of findings, preparation of submissions and development of defence strategies.
  • Assessment of operational strategies to adapt digital business models to regulatory developments and tax authorities’ interpretative practice.
  • Support in defining internal policies on pricing, promotions, contractual flows and data management for tax purposes.

Running e‑commerce, marketplaces or digital services and need to review your tax position?

Contact us to review your digital commerce flows, check tax compliance and design models aligned with VAT rules and e‑commerce regulations.