Tax Audits, Assessments and Pre‑Litigation Tools
The audit and assessment stage is often decisive for the outcome of a tax dispute. Ciani Partners assists taxpayers during tax audits and inspections, managing relationships with assessing bodies, handling discussions with the authorities and preparing technical defences from the very first interactions.
- Support during tax audits, including presence at inspections, analysis of proposed findings and preparation of written submissions, counter‑arguments and additional documentation.
- Assistance in reviewing invitations to discuss, tax audit reports and assessment notices, with a precise analysis of legal and evidentiary aspects.
- Targeted use of pre‑litigation settlement tools, such as settlement of assessments, acquiescence, facilitated settlements and other mechanisms designed to reduce penalties and avoid court proceedings.
- Design of defence strategies that take into account the impact on liquidity, reputation and relationships with banks and investors.
Appeals, Court Proceedings and Procedural Protection
Where administrative settlement is not possible or advisable, Ciani Partners represents taxpayers in court proceedings before the competent tax courts, handling the entire litigation process and coordinating, where appropriate, civil, criminal and corporate aspects linked to the dispute.
- Drafting of initial appeals and subsequent briefs, with robust legal reasoning, analysis of relevant case law and emphasis on the specifics of the case.
- Assistance in all levels of jurisdiction, including appeals and Supreme Court proceedings, with a careful assessment of costs, benefits and prospects of success at each stage.
- Coordination of tax, criminal and corporate dimensions of disputes, particularly where investigations into tax offences are connected to tax assessments.
- Management of interim measures and requests for suspension, paying close attention to the impact on business operations, cash flows and relationships with stakeholders.
Businesses, HNWIs and Multinational Groups
Tax disputes involving companies, high‑net‑worth individuals (HNWIs) and multinational groups frequently present heightened complexity, with implications for governance, reputation and long‑term strategy. Ciani Partners offers integrated management of such disputes, taking into account their overall impact on business models and asset structures.
- Assistance to companies and multinational groups in disputes concerning direct taxes, VAT, transfer pricing, withholding taxes and other levies, including cross‑border dimensions.
- Protection of HNWIs and families with complex wealth structures in disputes relating to tax residence, wealth planning arrangements, trusts, holding companies and planning instruments.
- Support in managing communication with governance bodies, investors and media where tax litigation has significant reputational implications.
- Integration of litigation defence with preventive reshaping of corporate and wealth structures to reduce the risk of future challenges.