crowe horwath italy tax - rome cross-border tax team
DESCRIPTION
Our cross-border tax team in RomeTRANSCRIPT
Cross-Border Tax Services Team
20 April 2012
Summary
• Team
• Activity
• Selected experience
• Professionals
Team • Gaetano Pizzitola, Partner
• Daniele Sabatini, Senior Manager
• Francescomaria Serao, Senior Manager
• Giovanni Ricco, Manager
• Luca Gasparrini, Manager
• Fabio Zampini, Manager
• Andrea Mrakic, Senior
• Marianna Delle Foglie, Senior
• Marta Selicato, Junior
Activity - Foreign investments in Italy
John Stewart Crowe Horwath ITD
• Tax advice and alerts on Italian tax developments and news
• Tax feasibility studies and tax review of financial models
• Investment structuring (eg, legal form, PE risk analysis, funding of the investment)
• Tax due diligence on Italian entities, with a specific focus on international tax issues
• Cash-flow optimization through the analysis and recovery of potential double taxation on, amongst
others, royalties, interest and dividends
• Italian entity conversion further to change of business models: eg, commissionaire, limited risk
distributor, toll and contract manufacturer, delocalization (unilateral and multilateral APA, new
agreements, PE issues, transfer of assets)
• Transfer pricing (documentation review and drafting, benchmark analysis, pricing policies’ setting)
• Advice and assistance on black-list costs (rulings, agreements and support documentation analysis)
• Assistance during tax audits, settlements and court cases on international tax matters (PE, transfer
pricing, black list costs, double tax treaties and EU tax law)
Activity - Italian investments abroad
John Stewart Crowe Horwath ITD
• Analysis of foreign tax regimes
• Tax alerts on foreign tax developments and news
• Analysis of PE risks
• Group tax cash-flow optimization through the analysis of double tax treaties and EU law and
recovery of potential double taxation on, amongst others, royalties, interest and dividends
• CFC and black-list issues management
• Setting / testing of transfer pricing policy (business model analysis/restructuring, unilateral and
multilateral APAs, documentation review and drafting)
• Tax structuring based on the group business model
• Investment structuring (legal form, PE risk analysis, funding of the investment, relationships with
other group entities)
• Coordination of tax services related to foreign consociated companies and branches
Selected experience
John Stewart Crowe Horwath ITD
• Assistance during and after tax audits on PE, transfer pricing, black list, CFC, withholding taxes
and abuse of law claims
• Settlements of PE and black list assessments by conversion into transfer pricing agreements
• Settlements and court cases on transfer pricing adjustments
• Implementation and audit defense of business restructuring projects (Chapter IX OECD TP
Guidelines)
• Advance Pricing Agreements (APAs)
• Transfer pricing documentation projects including management fees allocation and Master Files
• Ruling clearance on dormant companies regime, tax consolidation, black list, CFC and other
transactions
• Acquisition structuring and due diligence on Italian plants and assets, including real estate, solar
and wind farm projects
• Tax assistance on JV set-up and buy-out or divestiture
• IPO tax comfort letters
Leader Cross-Border Tax - Italy
Gaetano Pizzitola
Gaetano Pizzitola
+39 366 76 09 429
Business Experience
• Up to 2011: International Tax Partner in Ernst & Young and (2010-11)
International Tax Service leader of the Mediterranean sub-area (Italy, Spain and
Portugal). Formerly, supply-chain Italian tax leader and, from 1997 to 2000, head
of the EY Italian tax desk in New York. Former Italian corporate tax inspector,
Milan Revenue Office
• 25 years experience in international tax
• Gaetano holds a Law Degree from Palermo University, a Master in Taxation
from IPSOA-Kluwer Business School in Milan and an LL.M. in Taxation from
Queen Mary & Westfield College in London
Specializations and Focus industries
• Investments in Italy by foreign investors, supply-chain and business
restructuring
• Rulings, APAs and related settlements/controversy
• Tax audit controversy management
Tax Senior Manager
Daniele Sabatini
Daniele Sabatini
+39 329 6174725
Business Experience
• Professional experience of more than 20 years in the Italian Revenue
Authorities conducting inspections towards big companies.
• Daniele holds a Law Degree from Rome University, an Economic Degree from
Bologna University and Master in Taxation from IPSOA-Kluwer Business School
in Rome
Specializations and Focus industries
• International Tax
• Focus Industries: Permanent establishment, transfer pricing, CFC, Black list
International Tax and Transfer Pricing Senior Manager
Francescomaria Serao
+39 06 69 77 571
Business Experience
• Chartered accountant. Experiences in audit, financial planning and
management control. 4-year work experience in New York with 10 years of total
professional experience
• Francescomaria holds a Economic Degree from Federico II° University
in Naples
Specializations and Focus industries
• Transfer Pricing
• Focus Industries: energy, banks, health care, no profit
Francescomaria Serao
International Tax Manager
Giovanni Ricco
Giovanni Ricco
+39 06 69 77 571
Business Experience
• Attorney, with a total professional experience of 10 years
• Giovanni holds a Law Degree from Luiss Guido Carli University in Rome, and a
Master in Taxation from the Ministry of Finance
Specializations and Focus industries
• International and corporate taxation, real estate, capital markets and financial
transactions
• Focus Industries: real estate, banks, life insurances companies, mutual funds,
other financial intermediaries
International Tax Manager
Luca Gasparrini
Luca Gasparrini
+39 06 69 77 571
Business Experience
• Chartered accountant, with a total professional experience of 10 years
• Luca holds a Economic Degree from Bologna University and a Master in Tax
Law from Luiss Guido Carli University in Rome
Specializations and Focus industries
• International taxation, cross-border reorganizations and corporate taxation
• Focus Industries: automotive, pharmaceutical, commodities, oil & gas, energy
International Tax and Transfer Pricing Manager
Fabio Zampini
Fabio Zampini
+39 335 1533581
Business Experience
• Chartered accountant, with a total professional experience of more than 7
years
• Fabio holds an Economic Degree from the Link Campus University of Malta
and a Master in International Taxation from the IPSOA in Rome
Specializations and Focus industries
• Transfer pricing, business / supply chain restructuring, APAs
• Focus Industries: pharmaceutical, energy, oil & gas, consumer
International Tax Senior Consultant
Andrea Mrakic
Andrea Mrakic
+39 06 69 77 571
Business Experience
• A total professional experience of 6 years including work experiences in New
York and Luxembourg
• Andrea holds an Economic Degree from LUISS University in Rome and a
Master in Finance from Bocconi University in Milan
Specializations and Focus industries
• International taxation, financial services
• Focus Industries: banks, funds and other financial intermediaries
International Tax Senior Consultant
Marianna Delle Foglie
Marianna Delle Foglie
+39 06 69 77 571
Business Experience
• Attorney, with a total professional experience of 5 years
• Marianna holds a Law degree from Bari University and a Master in Tax Law
from the Sole 24 ore Business School in Milan
Specializations and Focus industries
• Corporate taxation, CFCs
International Tax Consultant
Marta Selicato
Marta Selicato
+39 06 69 77 571
Business Experience
• Corporate tax and international taxation consultant
• Marta holds a Law Degree from LUMSA University in Rome and a Master in
Corporate Tax Law from Bocconi University in Milan