Sara Armella

Sara Armella

Graduated in Law in 1993, cum laude and with honors, enrolled in the Law Society since 1996, practiced (1993-2008) with Prof. Victor Uckmar, for whom she did teaching for many years at the University of Genoa, there also earning her Ph.D. in 1999.

In 2008, he founded Studio Armella & Associati, with offices in Milan and Genoa, listed by leading independent research among the top professional firms, in Italy, in the fields of tax law, international trade law and customs.

Member of the Customs Expert Commission appointed by Deputy Minister of Finance Hon. Maurizio Leo for the implementation of tax reform.

Member of the International Customs Law Academy - ICLA, which has one hundred experts worldwide, since 2023 he is also a member of the Board of ICLA
President of the Customs & Trade Facilitation Commission of the Italian Section of the International Chamber of Commerce, Italian delegate to the corresponding Commission of ICC global.
Lecturer in customs law at Bocconi University, Università Statale di Milano and La Sapienza di Roma in Masters and Postgraduate Courses, he is contract professor at ICE.
Speaker at many international conferences, organized by WCO (World Customs Organization), International Customs Law Academy (ICLA) and European Commission.
He wrote the monographs "Customs Law of the European Union" (Egea-Università Bocconi, 2017) and "EU Customs Code" (Bocconi University Press, 2017).

He is the author of the entry "Customs Taxes" in the Treccani Encyclopedia Giuridica, as well as more than one hundred publications in national and international scholarly journals (including Global trade and Customs journal, Tributary Law and Practice, Tax Courier, Tax Law Journal).

He is a member of the Customs and International Trade Working Group of Confindustria.

Scientific director of Arcom Formazione, a school of advanced training for businesses and professionals.
With other leading international firms, founded Green lane, an association of independent firms specializing in international trade law and customs.
Independent board member of leading companies, chairman of the board of statutory auditors of Fondazione Enasarco, director of regency at Banca d'Italia, Genoa office.

Publications

Monographs

  • Customs Law of the European Union, Egea Bocconi, Milan, 2017
  • EU Customs Code, BUP, Milan, 2017
  • Customs Law, Egea Bocconi, Milan, 2015

Collaborations to institutional works

  • Customs Law of the European Union, in Derecho aduanero, Tomo II, edited by German Pardo Carrero, coordinated by S. Ibanez Marsilla and F.M. Yebra, ed. Universidad de Rosario and Tirant Lo blanch, Bogota, 2020;
  • Customs taxes, in Encyclopedia giuridica Treccani, Rome, 2015;
  • Fiscal Profiles and the Customs System, in VAT, Memento Ipsoa-Francis Lefebvre, Ipsoa, Milan, ed. 2011-2020;The territoriality of inheritance and gift tax, in Profession of Notary and the Relationship with the Tax Authorities, Altalex publisher, 2014;
  • The fight against tax evasion, in La normativa tributaria nella giurisprudenza delle Corti e nella nuova legislatura, Cedam, Padua, 2007;
  • Bank investigations, in Celt Tax Inspection Code, 2005;
  • Customs inspection, in Celt Tax Inspection Code, 2005;
  • Customs duties in Corso di diritto tributario internazionale, coordinated by V. Uckmar, Cedam, Padua, 3rd ed., 2005;
  • Customs taxes. European Union, in Impuestos sobre el commercio internacional, coordinated by V. Uckmar, A. Altamirano, H. Torres, Buenos Aires, 2003;
  • VAT territoriality, in Guida alla lettura della giurisprudenza tributaria, coordinated by G. Visentini, Giuffrè, Milan, 2003;Soggetti passivi Iva, in Guida alla lettura della giurisprudenza tributaria, coordinated by G. Visentini, Giuffrè, Milan, 2003;
  • The Right to Information in Customs Matters, in The Right to Interpret. Tax ruling-Community customs information-Taxpayer's rights, coordinated by G. Rebora, R. Ruffini and G. Terracciano, De Agostini professional, Rome, 2001;
  • Tax entries in the series I contratti, Ipsoa, Milan, 1995-2006;
  • Tax references, in AA.VV., Contracts 2001, coordinated by V. Cuffaro, Ipsoa, Milan, 2001;
  • Studies on the Constitution and Tax Legislation of Russia and Luxembourg, in I modi di formazione della legge, C.N.R. Strategic and Finalized Project, coordinated by Prof. Piera Filippi;
  • The tax regime of indivisible reserves, in La società cooperativa: aspetti civilistici e tributari, coordinated by G. Schiano di Pepe and F. Graziano, Cedam, Padua, 1997;
  • Le scissioni, in AA.VV., Diritto tributario delle società, vol. IV of the series Trattato teorico pratico delle società, coordinated by G. Schiano di Pepe, Ipsoa, Milan, 1997.

Articles

  • Brexit: what changes, in Vat, 2021;
  • Olaf reporting on possible violations alone is not enough for customs audit, in GT-Review of Tax Jurisprudence, 2021;
  • Brexit: possible scenarios on EU-UK relations, in Corr. trib., 2020;
  • Excluding the punitive nature of antidumping duties, in Corr. trib., 2020;
  • Royalties taxed only if factual indicators of licensor control are present, in GT, 2020;
  • The Vat taxability of international services rendered in ports and airports, in The Vat, 2020;
  • Unlawful collection of customs duties if the Commission annuls the assessment, in The Vat, 2020;
  • Customs penalty discipline between domestic norm and European principles, in Riv. dir. trib., 2020;
  • The new excise discipline, in The Vat, 2020;
  • Customs duties and import VAT: distinct taxation prerequisites according to the European Court of Justice, in Riv. dir. trib., 2020;
  • The indirect representative is not taxable for import VAT, in Corr. trib., 2020;
  • WTO Agreement on Trade Facilitation (TFA): General Rules on Simplification, Harmonization and Modernization of Administrative Procedures, in Global Trade and Customs Journal, 2019;
  • The test of non-taxability of intra-Community transactions between case law and the 2020 reform, in GT-Review of Tax Jurisprudence, 2019;
  • Anti-dumping duty unlawful if the right of defense is violated, in Corr.trib., 2019;
  • The payment file is valid if the prodromal act was duly served, in GT-Review of Tax Jurisprudence, 2019;
  • Undeclared and unused VAT credit is not a mere formal violation, in GT-Review of Tax Jurisprudence, 2019;
  • Pre-assessment cross-examination again under scrutiny by the EU Court, in Corr.trib., 2018;
  • Trademarks and royalties: customs and VAT taxability conditions, in Corr.trib., 2018;
  • Customs value assessment and the function of databases, in Corr. trib., 2018;
  • Tax cooperation between EU countries and taxpayer protection, in Corr. trib., 2017;
  • Are indirect taxes the general charges of the electricity system, in Corr. trib., 2017;
  • Passive subjectivity of the customs debt in the new HRC, in Corr. trib., 2017;
  • Tax monitoring regulations are only effective "pro futuro". Limits to the usability of the Falciani list, in GT, 2017;
  • Prescription of customs assessment and decriminalization, in Corr. trib., 2016;
  • Is the administrative suspension of customs enforcement conditional on security legitimate?, in Corr. trib., 2016;
  • Customs "compliance" tools in light of the new Union Code, in Corr. trib., 2016;
  • New Union Customs Code: what changes in customs value rules, in Corr. trib., 2016;
  • Olaf reporting alone does not justify customs assessment, in The Vat, 2016;
  • The main new features of the new Union Customs Code, in Corr. trib., 2016;
  • Usability of the Vaduz list and illegitimate evidence in the tax process, in Corr. trib., 2016;
  • Notice of crime and limitation period of customs assessment, in Corr. trib., 2016;
  • Tax administration recognizes "transfer pricing" values even for customs purposes, in Corr. trib., 2016;
  • Applicability of esterovestification to structures not of "pure artifice"?, in Corr. trib., 2016;
  • Supplier liability in the case of habitual exporter fraud, in The Vat, 2016;
  • Declarations containing multiple singles: legitimate offsetting for penalty calculation, in The Vat, 2016;
  • Expanded cases of "exit tax" deferral, in Corr. trib., 2015;
  • "Virtual" use of VAT warehouse: the Supreme Court radically changes direction, in Corr. trib., 2015;
  • "Anti-dumping" duties: cases of refund, in Corr. trib., 2015;
  • Falciani list allowed to be used for tax assessments, but is mere clue, in Corr. trib., 2015;
  • "Cumulative" letters of intent in customs, in Corr. trib., 2015;
  • Customs "status" of "containers" is decisive for territoriality, in Corr. trib., 2015;
  • The "first sale price" method: legitimate savings on customs duties, in Corr. trib., 2015;
  • Direct representation in Customs even for domiciled procedure, in Corr. trib., 2015;
  • Stop subjectivity disputes, in GT, 2015;
  • Quotas and limits on imports to Russia, in The Vat, 2015;
  • Recent applications of the preferential origin discipline, in The Vat, 2015;
  • Customs declarations: errors not compensable, in The Vat, 2015;
  • Customs inspections and the prior adversarial process, in The Vat, 2015;
  • The Classification Regulations do not apply retroactively, in The Vat, 2015;
  • VAT deductibility resulting from subjectively nonexistent invoices if there is good faith, in The Vat, 2015;
  • Customs duties: limitless collection, but not retroactive, in The Vat, 2015;
  • No black list penalties if company submits supplementary return, in Tax News, 2014;
  • Customs: doubts about the new discipline of collection in the course of the judgment, in Corr. trib., 2014;
  • The indirect representative is not liable for import VAT, in The Vat, 2014;
  • The effects of the "Equoland" ruling on the VAT treatment of "royalties," in Corr. trib., 2014;
  • Recent jurisprudential developments on tax duplication, in The Vat, 2014;
  • Commissions on purchase and sale and customs value of goods, in The Vat, 2013;
  • Online sales: subjects liable from non-payment of customs duties, in The Vat, 2013;
  • Administrative cooperation on excise taxes, in The Vat, 2013;
  • Customs' "new" jurisdiction is not retroactive, in The Vat, 2013;
  • Evolution and problems of the right to excise rebate, in The Vat, 2013;
  • Interpretive insights for the inward processing regime, in The Vat, 2013;
  • The right to advance adversarial proceedings in customs matters, in The Vat, 2013;
  • The use of wiretaps in tax proceedings and the delicate balance with the right of defense and the principle of due process, in GT, 2013;
  • The difficult protection from enforceability of correction acts issued by the Customs Agency, in Corr. trib., 2013;
  • Crime of smuggling and unity of VAT, in Corr. trib., 2013;
  • Competitive pricing and on-time delivery justify blacklisted costs, in Corr. trib., 2013;
  • Effects of the double tax treaty between Italy and San Marino, in Corr. trib., 2013;
  • Evidence of export alternatives to SAD and exit results, in Corr. trib., 2013;
  • Recent jurisprudential developments on tax duplication, in The Vat, 2012;
  • The instruments of protection against dumping practices, in The Vat, 2012;
  • Conditions for AEO grant narrowed: more constraints on trader status, in The Vat, 2012;
  • Territorial competence of the Customs Agency and illegality of assessment acts, in The Vat, 2012;
  • "Made in Italy" violations and new powers for Chambers of Commerce, in The Vat, 2012;
  • Can the regular exchange of information between states heal the original illegality of the Falciani list? in Corr. trib., 2012;
  • Transportation costs: customs regulations and vat, in The Vat, 2012;
  • The instruments of protection against "dumping" practices, in The Vat, 2012;
  • Conditions for AEO grant narrowed: more vehicles for trader status, in The Vat, 2012;
  • "Exit Tax" suspended taxation of latent capital gains until actual realization, in Corr. trib., 2012;
  • Taxation of dividends based on the actual residence of the recipient, in Corr. trib., 2012;
  • Doubling of assessment period does not operate if criminal complaint is missing, in Corr. trib., 2012;
  • Enhancement of customs assessment and new penalty regime, in The Vat, 2012.
  • "Amnestied" years for VAT purposes, doubling of time limits and time-barred offenses, in Corr. trib., 2012;
  • "Exit tax": taxation of latent capital gains suspended until actual realization, in Corr. trib., 2012;
  • Uncertainty about the criminal relevance of abuse of right and doubling of time limits, in Corr. trib., 2012;
  • The customs value of goods in intercompany relations, in The Vat, 2012;
  • The critical aspects of abuse of right in indirect taxation, in Corr. trib., 2012;
  • Failure to submit the guarantee in the VAT group scheme cannot be sanctioned in the same way as evasion, in GT, 2011;
  • Place of taxable transactions: EU definitions force a review of domestic law, in Corr. trib., 2011;
  • For predominantly mutual cooperatives "2010 assessments" without use of sector studies, in Corr. trib., 2011;
  • The notion of residence for vat purposes does not correspond to that provided for direct tax purposes, in Corr. trib., 2011;
  • New rules on ascertaining the customs origin of goods, in The Vat, 2011;
  • Protection of the taxpayer: prior interpellation and binding information, in The Vat, 2011;
  • Tax deposits for VAT purposes: issues still open, in The VAT, 2011;
  • New guidelines on the precautionary suspension of customs assessments, in The Vat, 2011;
  • Tax requirements for VAT purposes: issues still open, in The VAT, 2011;
  • Place of taxable transactions: EU definitions force a review of domestic law, in Corr. trib., 2011;
  • New VAT territoriality and discipline of non-taxability, in The Vat, 2011;
  • The notion of residence for VAT purposes does not correspond to that provided for direct tax purposes, in Corr. trib., 2011;
  • For predominantly mutual cooperatives "2010 assessments" without use of sector studies, in Corr. trib., 2011;
  • Customs clarifications on new export rules, in The Vat, 2011;
  • "Emission trading" transactions: legal qualification affects territoriality, in Corr. trib., 2011;
  • The Supreme Court expands the crime of import VAT evasion, in GT, 2011;
  • Importer liability in case of inaccurate certificates of origin, in The Vat, 2011;
  • Place of taxable transactions: definitions force a review of domestic law, in Corr. trib., 2011;
  • Liability profiles of customs agents, in The Vat, 2011;
  • Failure to submit the guarantee in group VAT cannot be sanctioned in the same way as evasion, in GT, 2011;
  • Invalid customs assessment acts without pre-dispute, in The Vat, 2011;
  • The statute of limitations for customs assessment, in The Vat, 2010;
  • The value of goods relevant to customs and royalties, in The Vat, 2010;
  • Is import VAT distinct and autonomous from domestic VAT?, in Corr. trib., 2010;
  • Are sector studies applicable to cooperative societies?, in Corr. trib., 2010;
  • In the customs sector, a restrictive ruling by the Supreme Court, in GT, 2010;
  • Prescription of the customs debt and the necessary coordination of the EU rule with the national rules, in GT, 2009;
  • Good faith of the importer and liability for invalidity of certificates, in GT, 2007;
  • Manoeuvre bis: established registry of financial reports, in Dir. prat. trib, 2006;
  • Hints on the composition agreement and assessment reform, in Corr.trib., 2003;
  • Customs authorities' error precludes duty recovery, in Dir.prat.trib.int., 2003;
  • Proof of export. Important clarifications by the Customs Agency, in Corr.trib., 2003;
  • The notion of residence in EU and domestic law, in Corr.trib., 2002;
  • The proof of export, in The Vat, 2002;
  • Problematic aspects related to the application of customs sanction discipline, in Corr.trib., 2001;
  • The VAT regime of port and airport services, in Corr.trib., 2001;
  • Interpretive criteria on VAT territoriality of services, in Corr.trib., 2001;
  • Notes on the notion of customs duty in domestic and international regulations, in Riv.dir.trib., 2001;
  • Brief notes on the compatibility of indirect taxes with EU VAT and excise regulations and on the recovery of undue payment, in Riv.dir.trib., 2000;
  • The VAT regime of electronic commerce, in Dir.prat.trib., 1999;
  • The notion of economic activity for VAT purposes, in Dir.prat.trib., 1999;
  • The VAT regime of means of transport leasing transactions in the EU context, in Riv.dir.trib., 1998;
  • The VAT regime of arbitration services, in Dir.prat.trib., 1998;
  • The VAT regime of travel agencies, in Riv. dir. trib., 1997;
  • The V.A.T. regime of international and EU transportation of goods and persons, in Dir. prat. trib., 1997;
  • For the Court of Justice, even the copy of the passive invoice legitimizes the VAT deduction, in Riv. dir. trib., 1997;
  • Observations on taxes of equivalent effect, prohibition of discrimination and recovery of undue payment, in Riv. dir. trib., 1996;
  • ICI in the case of surface ownership, in Dir. prat. trib., 1996;
  • EC Court of Justice declares default interest on VAT due upon final importation undue, in Dir. prat. trib., 1996;
  • The time of taxation of services passes the scrutiny of the EC Court of Justice, in Dir.prat.trib., 1996;
  • The reserves of cooperative societies and Article 12 l. 904/1977, in Dir. prat. trib., 1996;
  • Indeductible ransom paid for the release of kidnapped "manager," in Dir. prat.trib., 1995;
  • Retroactive taxation of expropriation compensation: interpretative problems and doubts of constitutional legitimacy, in Dir. prat. trib., 1995;
  • Jurisprudential, administrative and doctrinal guidelines on insurance tax, in Dir. prat. trib., 1994;
  • Trespassing from the customs ceiling: what penalty discipline?, in Dir. prat. trib., 1994;
  • On the deduction of the improvement contribution from the Invim, in Dir. prat. trib., 1993.

Information

  • Name:

    Sara Armella
  • Role:

    Founder
  • Qualification:

    Founder Studio Armella
  • Skills:

    Tax Law
  • Languages:

    English, French
logo
logo

International legal and tax consulting

Contact us

Operating Locations

Via Torino, 15/6 - 20123 Milan
Piazza De Ferrari, 4/2 - 16121 Genoa