Domestic and International Taxation

• Tax consulting and compliance support
• Protection of Businesses in the Pre-litigation Phase
• Tax Litigation Management
• Legal representation at all levels of the court system, up to the Supreme Court
• Legal representation in proceedings before:
• • Court of Justice of the European Union
  • European Court
  • Constitutional Court
• Taxation of the Boating Industry

Tax Planning and Management of Intra-Group Transactions

Armella & Associati Law Firm assists companies and multinational groups in structuring cross-border transactions and managing the tax aspects associated with operating in multiple jurisdictions. We offer legal support in international tax planning, as well as in the drafting and review of intra-group contracts , and in the analysis of allocation of costs among affiliated companies, ensuring compliance with local regulations and OECD guidelines. The goal is to optimize overall tax liability, prevent double taxation, and minimize tax risks.

Transfer pricing and corporate residency

A specific section is devoted to transfer pricing, an area in which we assist clients in preparing supporting documentation, analyzing controlled transactions, and defining group policies. The firm also provides services related to assessing the tax residency of companies, with a focus on issues related to offshore shifting, permanent establishments, and economic nexus, providing solutions that comply with Italian law and international standards.

Individual Income Tax and Tax Incentive Schemes

We also provide consulting services to managers, directors, and high-net-worth individuals with significant international mobility, addressing issues related to tax residency of individuals, the taxation of foreign income, and cross-border wealth management. Particular attention is given to the the repatriate regime and other tax incentives designed for taxpayers who transfer their residence to Italy. The Firm also assists in preventing disputes related to residency and in tax assessment proceedings.

Tax consulting and representation during audits

Armella Law Firm offers highly qualified legal advice and assistance in the field of national tax law, supporting businesses, corporate groups, cooperatives, third-sector entities, and private taxpayers in managing the most complex tax issues. Our practice focuses on every stage of the relationship with the tax authorities, from tax audits to pre-litigation settlements, through to potential litigation or collection proceedings.

Litigation-reduction tools and tax audit management

During tax audits, the firm provides immediate operational support, including assistance with the preparation of defense briefs and responses, as well as the management oftax settlement or requests for self-defense, in accordance with the Taxpayer Bill of Rights. In the corporate sector, we offer sound advice on corporate and group taxation, inductive assessments of business income , and on tools to combat tax evasion, such as sector studies and synthetic tax reliability indices.

Local Tax Department

Armella & Associati Law Firm offers specialized services in local taxation, tailored to businesses, public entities, and individuals who require expert assistance in the management and litigation of municipal and provincial taxes.

We specialize in:

• IMU, TARI, TASI, and other property taxes: analysis of tax liability, verification of the accuracy of tax assessments and payment notices, and preparation of petitions and appeals.
• Local tax consulting and planning: strategic support for property management and the planning of initiatives involving significant real estate portfolios.
• Litigation defense: representation before tax courts and assistance at all stages of litigation with tax authorities.
• Out-of-court assistance: liaising with tax offices and collection agencies to resolve disputes amicably and manage installment plans or tax relief.

Our approach combines legal, tax, and administrative expertise, with the aim of ensuring that our clients receive transparent, efficient service that complies with current regulations.