Ciani Partners | International Tax

International Tax Law

International and EU Tax Law advisory

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Ciani Partners | Avvocati Tributaristi Milano

International Tax Advisory

International Tax Advisory

International Tax Law Mastery: Precision, Strategy, and Excellence in Cross-Border Advisory and EU Tax

Increasing globalisation and intensified scrutiny by tax authorities require a strategic and highly qualified approach to cross-border tax matters and international tax disputes. Ciani Partners provides advanced legal advisory services in the field of International Tax Law and EU Tax Law, assisting both individuals and HNWIs (High-Net-Worth Individuals) as well as domestic businesses and multinational groups. Our team supports clients in tax audits, cross-border transactions and international tax planning, delivering tailored solutions for compliance, tax optimisation and the prevention of tax litigation.

Service Overview

Ciani Partners is highly specialised in counselling on International Tax Law and EU Tax Law. Our team provides advanced assistance in tax audits, assessments, cross-border transactions, tax litigation and global tax compliance, ensuring full adherence to BEPS (Base Erosion and Profit Shifting), Pillar 2 and the ATAD Directive (Anti-Tax Avoidance Directive).

With a multidisciplinary approach, we support businesses and individuals in structuring international transactions, planning cross-border tax strategies and managing complex disputes. Ciani Partners is recognised as a benchmark in international tax advisory, known for the quality of its services and its personalised, client‑centric approach.

Areas of Assistance

The evolution of international tax rules requires advanced specialist advice aimed at resolving the most complex tax disputes and optimising the defence strategy in high-impact litigation. Ciani Partners provides highly qualified assistance in the following areas:

  • Support in disputes concerning the qualification of beneficial owner and legal owner in the cross-border distribution of dividends, interest and royalties, as well as the application of the Interest and Royalties Directive.
  • Support in matters involving artificial entities and verification of actual control over income flows under the Business Purpose Test and Principal Purpose Test (BEPS Action 6).
  • Strategic advice on the relocation of business activities to Italy, including compatibility with State aid rules and the regime provided by Article 6 of Legislative Decree 209/2023.
  • Assistance in determining permanent establishment, defence against sham residence challenges and computation of foreign permanent establishment income under the branch exemption regime.
  • Advice on Participation Exemption (PEX), participatory financial instruments and disputes relating to the taxation of capital gains.
  • Assistance in economic substance reviews and defence in proceedings aimed at challenging the effective ownership of cross-border income.

Companies and Multinational Groups

Businesses operating internationally face increasing tax complexity and require strategic tax compliance management to reduce litigation risk and optimise tax costs. Ciani Partners advises multinational groups and companies with cross-border interests in international tax disputes, tax planning and high-impact tax controversy matters.

  • Disputes relating to aggressive tax planning practices aimed at artificially reducing the tax base in breach of international standards.
  • Assistance in matters arising from the implementation of BEPS Pillar 2 measures introducing a global minimum tax for multinational groups.
  • Litigation involving the application of EU anti-avoidance measures designed to ensure proper taxation across Member States.
  • Advice on international tax treaties, including disputes concerning the interpretation and application of bilateral double tax conventions.
  • Defence in disputes involving the correct application of VAT rules in cross-border transactions.
  • Advice on transfer pricing, relocation of business activities and the tax valuation of transferred assets.
  • Assistance in the tax management of extraordinary transactions with international implications, including M&A deals and cross-border reorganisations.

Individuals and HNWIs

Individuals with international assets and economic interests face a complex transnational tax framework. Ciani Partners assists individuals and HNWIs with a personalised and strategic approach to international tax management, combining legal advice, tax planning and defence in high-stakes disputes.

  • Advice on transferring tax residence to Italy, with a focus on the flat tax regime for new residents, RW reporting exemptions and the inbound workers regime.
  • Assistance in claiming and defending foreign tax credits relating to income produced abroad.
  • Defence against challenges by the tax authorities concerning effective tax residence, sham residence allegations and hidden permanent establishment issues.
  • Specialised advice in disputes concerning tax residence, fictitious relocation and cross-border audit procedures.
  • Support in the application of the Res-Non-Dom tax regime and in broader international tax optimisation strategies.
  • Legal and tax assistance in matters involving foreign assets, undeclared income, tax violations and tax crime risk.
  • Advice on the taxation of participatory financial instruments held by individuals resident in Italy or abroad.
  • Assistance with family wealth protection, cross-border succession planning and the regularisation of foreign assets and income.

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