Tax Litigation, MAP and Tax Controversy

We defend companies, multinational groups and resident and non-resident individuals in all phases of tax controversy — from pre-litigation to the Supreme Court — across all direct and indirect taxes. The firm combines a solid tradition of advocacy before the tax courts with consolidated experience in international disputes (MAP, EU tax arbitration), in close coordination with the Taxand network in counterpart jurisdictions.

We support clients from the tax audit phase onwards, handling documentary requests, the findings of the tax assessment report (PVC) and preventive cross-examination strategies. We define the best procedural strategy, weighing in an integrated manner the deflationary instruments (assessment with adherence, judicial settlement, voluntary disclosure), out-of-court settlements and the judicial option, also in coordination with any tax-criminal profiles.

We work in coordination with criminal defence lawyers, overseeing the point of contact between tax law, administrative practice and criminal offences.

Areas of focus

• Tax audits, preventive cross-examination, management of PVC and tax assessment notices.
• Deflationary instruments: assessment with adherence, judicial and out-of-hearing settlement, voluntary disclosure.
• Advocacy before the Tax Courts of first and second instance, Supreme Court tax division.
• MAP (Mutual Agreement Procedure) and arbitration procedures under EU Directive 2017/1852 and bilateral conventions.
• Transfer pricing, beneficial ownership, tax residence and permanent establishment litigation.
• Tax-criminal opinions and integrated risk management: assistance on offences under Legislative Decree 74/2000, support to corporate bodies on tax choices with criminal relevance, coordination with the criminal defence counsel.