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• 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 John Stewart agreements, PE issues, transfer of assets) Crowe Horwath ITD• 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• 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) John Stewart• Tax structuring based on the group business model Crowe Horwath ITD• 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• 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 John Stewart• Ruling clearance on dormant companies regime, tax consolidation, black list, CFC Crowe Horwath ITD 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 - ItalyGaetano Pizzitolagaetano.email@example.com+39 366 76 09 429Business Experience• Up to 2011: International Tax Partner in Ernst & Young and (2010-11)International Tax Service leader of the Mediterranean sub-area (Italy, Spain andPortugal). Formerly, supply-chain Italian tax leader and, from 1997 to 2000, headof 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 Gaetano Pizzitolafrom IPSOA-Kluwer Business School in Milan and an LL.M. in Taxation fromQueen Mary & Westfield College in LondonSpecializations and Focus industries• Investments in Italy by foreign investors, supply-chain and businessrestructuring• Rulings, APAs and related settlements/controversy• Tax audit controversy management
Tax Senior ManagerDaniele Sabatinidaniele.firstname.lastname@example.org+39 329 6174725Business Experience• Professional experience of more than 20 years in the Italian RevenueAuthorities conducting inspections towards big companies.• Daniele holds a Law Degree from Rome University, an Economic Degree fromBologna University and Master in Taxation from IPSOA-Kluwer Business Schoolin RomeSpecializations and Focus industries Daniele Sabatini• International Tax• Focus Industries: Permanent establishment, transfer pricing, CFC, Black list
International Tax and Transfer Pricing Senior ManagerFrancescomaria Seraofrancescomaria.email@example.com+39 06 69 77 571Business Experience• Chartered accountant. Experiences in audit, financial planning andmanagement control. 4-year work experience in New York with 10 years of totalprofessional experience• Francescomaria holds a Economic Degree from Federico II° Universityin Naples Francescomaria SeraoSpecializations and Focus industries• Transfer Pricing• Focus Industries: energy, banks, health care, no profit
International Tax ManagerGiovanni Riccogiovanni.firstname.lastname@example.org+39 06 69 77 571Business Experience• Attorney, with a total professional experience of 10 years• Giovanni holds a Law Degree from Luiss Guido Carli University in Rome, and aMaster in Taxation from the Ministry of FinanceSpecializations and Focus industries Giovanni Ricco• International and corporate taxation, real estate, capital markets and financialtransactions• Focus Industries: real estate, banks, life insurances companies, mutual funds,other financial intermediaries
International Tax ManagerLuca Gasparriniluca.email@example.com+39 06 69 77 571Business Experience• Chartered accountant, with a total professional experience of 10 years• Luca holds a Economic Degree from Bologna University and a Master in TaxLaw from Luiss Guido Carli University in RomeSpecializations and Focus industries Luca Gasparrini• International taxation, cross-border reorganizations and corporate taxation• Focus Industries: automotive, pharmaceutical, commodities, oil & gas, energy
International Tax and Transfer Pricing ManagerFabio Zampinifabio.firstname.lastname@example.org+39 335 1533581Business Experience• Chartered accountant, with a total professional experience of more than 7years• Fabio holds an Economic Degree from the Link Campus University of Maltaand a Master in International Taxation from the IPSOA in RomeSpecializations and Focus industries Fabio Zampini• Transfer pricing, business / supply chain restructuring, APAs• Focus Industries: pharmaceutical, energy, oil & gas, consumer
International Tax Senior ConsultantAndrea Mrakicandrea.email@example.com+39 06 69 77 571Business Experience• A total professional experience of 6 years including work experiences in NewYork and Luxembourg• Andrea holds an Economic Degree from LUISS University in Rome and aMaster in Finance from Bocconi University in MilanSpecializations and Focus industries Andrea Mrakic• International taxation, financial services• Focus Industries: banks, funds and other financial intermediaries
International Tax Senior ConsultantMarianna Delle Fogliemarianna.firstname.lastname@example.org+39 06 69 77 571Business Experience• Attorney, with a total professional experience of 5 years• Marianna holds a Law degree from Bari University and a Master in Tax Lawfrom the Sole 24 ore Business School in MilanSpecializations and Focus industries Marianna Delle Foglie• Corporate taxation, CFCs
International Tax ConsultantMarta Selicatomarta.email@example.com+39 06 69 77 571Business Experience• Corporate tax and international taxation consultant• Marta holds a Law Degree from LUMSA University in Rome and a Master inCorporate Tax Law from Bocconi University in Milan Marta Selicato
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