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.