Domestic and international taxation

• Tax consulting and compliance assistance
• Protection of enterprises in the pre-litigation phase
• Management of tax litigation
• Assistance in the various levels of justice, up to the Court of Cassation
• Assistance in proceedings before:
• • Court of Justice of the European Union
  • European Court
  • Constitutional Court
• Taxation of boating

Tax planning and management of intercompany relations

Armella & Associati Law Firm assists multinational companies and groups in structuring cross-border transactions and managing the tax aspects associated with being present in multiple jurisdictions. We offer legal support in international tax planning, in the drafting and review of intercompany contracts and in the analysis of allocation of costs between related companies, ensuring compliance with local regulations and OECD guidelines. The goal is to optimize overall taxation, preventing double taxation and minimizing tax risks.

Transfer pricing and corporate residency

A specific focus is devoted to transfer pricing, an area in which we support clients in the preparation of supporting documentation, the analysis of controlled transactions and the definition of group policies. The firm also intervenes in the assessment of the tax residence of companies, with attention to issues of esterovestizione, permanent establishment and economic nexus, providing solutions in accordance with Italian regulations and international principles.

Taxation of individuals and preferential regimes

We also advise managers, administrators and individuals with high international mobility, addressing issues related to the tax residence of individuals, foreign income taxation and cross-border wealth management. Particular attention is devoted to the repatriate regime and other tax attraction instruments aimed at taxpayers who transfer their residence to Italy. The firm also assists in the prevention of residence-related disputes and in assessment proceedings.

Tax advice and defense during audits

The Armella Firm offers highly qualified legal advice and assistance in the areas of national tax law, working alongside companies, corporate groups, cooperatives, Third Sector entities and private taxpayers in handling the most complex tax issues. The activity focuses on every stage of the relationship with the tax authorities, from tax audits to pre-litigation settlement, to eventual litigation or collection.

Litigation-deflating tools and assessment management

In the course of tax audits, the firm provides immediate operational support, including in the preparation of defense briefs, observations and in the management of theassessment with adhesion or petitions in self-protection, in accordance with the Statute of Taxpayers' Rights. In the corporate sphere, we offer sound advice on the corporate and group taxation, on inductive assessments of business income and on anti-avoidance tools such as sector studies and synthetic indices of tax reliability.

Local Tax Service

The Armella & Associates Law Firm offers specialized service in Local Taxes, aimed at businesses, entities and individuals who need qualified assistance in the management and litigation related to municipal and provincial taxes.

We deal with:

• IMU, TARI, TASI and other property taxes: analysis of tax position, verification of correctness of assessments and payment notices, preparation of petitions and appeals.
• Local tax consulting and planning: strategic support in property management and planning for significant real estate assets.
• Litigation defense: representation before the Tax Courts and assistance in all stages of litigation with tax authorities.
• Out-of-court assistance: liaison with tax offices and collection companies for amicable settlement of disputes and management of installment plans or relief.

Our approach combines legal, tax and administrative expertise, with the goal of ensuring that our clients are managed transparently, efficiently and in line with current regulations.