Tax Governance, Cooperative Compliance and Tax Technology

We support large taxpayers, multinational groups, banks and insurance companies in the design and implementation of Tax Control Frameworks consistent with the Italian cooperative compliance regime and OECD standards. We work at the intersection of taxation, corporate governance and internal control systems, integrating tax expertise with knowledge of compliance processes and technologies.

We assist businesses in tax risk mapping, in the definition of policies and procedures, in the preventive dialogue with the Italian Revenue Agency, in the management of tax rulings and in the adoption of tax technology solutions — including AI tools applied to compliance, real-time risk monitoring and audit trail.

We accompany businesses throughout the entire journey: from the adoption of the TCF to its certification, from risk mapping to structured dialogue with the Agency, with an approach that integrates method, governance and technology.

The spread of artificial intelligence is transforming the Tax Control Framework: a shift from deterministic logic to probabilistic models of risk detection, automated audit trails, continuous monitoring of tax flows, predictive classification of transactions. We support clients in the governance of these tools — selection, validation, human oversight, accountability under the EU AI Act — and in the related dialogue with the Tax Authorities, themselves increasingly oriented towards data-driven controls (ISA indices, synthetic indicators, fiscal big data).

Areas of focus

  • Tax Control Framework: design, implementation, maintenance and periodic audit.
  • Cooperative compliance: access to the regime, risk mapping, preventive dialogue with the Agency.
  • Tax technology: AI tools for compliance, process automation, governance of tax data.
  • DAC6, DAC7, DAC8: reporting obligations for intermediaries.
  • Tax offences, oversight of tax-criminal risk, updating of organisational models.
  • Ordinary tax rulings, new investments rulings, abuse of law and disapplication rulings.
  • TCF certification: preparation, support to the independent certifier.
  • EU AI Act and governance of artificial intelligence in tax matters: model validation, human oversight, accountability of corporate bodies.
  • Data-driven controls by the Italian Revenue Agency: ISA indices, synthetic indicators, fiscal big data, automatic exchange of information and new forms of algorithmic selection.