Profile: Studio Associato Servizi Professionali Integrati                                                            Last ...
The FirmCrowe Horwath - Studio Associato Servizi Professionali Integrati is a leading Italian professional services firm o...
Membership of Crowe Horwath InternationalCrowe Horwath International, one of the top 10 global accounting firms, is an int...
Value added servicesThe Firms strategy is to focus on the highest-standard specialisations in the different areas of law, ...
Some major clients                     Energy and Utilities           Transportation and logistic                       IC...
SASPI specialisations                              Consultancy                                ■   Ordinary current taxatio...
SASPI specialisations                              Inbound – Foreign investors in Italy                                ■  ...
SASPI specialisations                              Consultancy                                ■   Planning VAT and Customs...
SASPI specialisations                              Consultancy                                ■   Analysis of the supply c...
SASPI specialisations                              Tax litigation                                ■    Tax rulingsCorporate...
SASPI specialisations                              Consultancy                                ■   Company bylaws and share...
SASPI specialisations                              Contracts                                ■   Purchase and sale, agency,...
SASPI specialisations                              Labour                                ■   Company restructuringsCorpora...
SASPI specialisations                              Trade union relations                                ■    Assistance in...
Our main offices and contacts     Milan                                               Rome                 Via della Mosco...
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Crowe Horwath Italy Tax-Legal Firm Presentation

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Crowe Horwath Italy Tax-Legal Firm Presentation

  1. 1. Profile: Studio Associato Servizi Professionali Integrati Last update: April 2012
  2. 2. The FirmCrowe Horwath - Studio Associato Servizi Professionali Integrati is a leading Italian professional services firm offering legal, tax andlabour law consultancy.With more than 130 professionals and offices in Milan, Rome, Turin and Venice, the Firm offers high-level professional consultancy,integrating varied professional experience with sector specialisations, in the following areas: ■ Corporate Taxes; ■ Cross-Border Tax; ■ VAT and Customs; ■ Transfer Pricing; ■ Tax Litigations; ■ Legal and Corporate Affairs; ■ Labour Law and Consultancy.The Firm is a member of Crowe Horwath International - one of the top 10 global networks - and a privileged partnerof FIS-Antex group, which provides Human Resource and Finance & Administration services in outsourcing.Crowe Horwath - Studio Associato Servizi Professionali Integrati collaborates with a number of leading professional figures, alsothrough an important partnership with the team of labour law experts coordinated by Prof. Tiziano Treu and Prof. Angelo Pandolfo. 2
  3. 3. Membership of Crowe Horwath InternationalCrowe Horwath International, one of the top 10 global accounting firms, is an international Network with 167 independent accountingand advisory services firms, 650 offices and more than 28,000 professionals and staff in 109 countries around the world.Crowe Horwath Internationals member firms are committed to impeccable quality service, highly integrated service delivery processesand a common set of core values that guide our decisions daily.Each firm is well-established as a leader in its domestic market and, thanks to the in-depth knowledge of local laws and customs of itsprofessionals, supports clients undertaking new ventures or expanding into other countries. 3
  4. 4. Value added servicesThe Firms strategy is to focus on the highest-standard specialisations in the different areas of law, whilst maintaining aninterdisciplinary spirit of teamwork amongst its professionals. This approach enables us to provide clients with timely responsesaimed at resolving specific problems.In addition to ordinary professional activities, our Firm provides a series of distinctive services free of charge. These include: ■ Workshops – seminars on legislative changes and subjects of interest to companies ■ Periodic newsletters commenting on changes in labour, tax, company law ■ In-depth analyses of specific subjects ■ Access to Antexnews, a labour law website.Other value added services include: ■ Specialised training courses for the company’s management ■ Ad hoc training courses for companies on specific subjects.Crowe Horwath - Studio Associato Servizi Professionali Integrati has an internal research department (Centro Studi) dedicated toensuring: ■ that the firm’s professionals are constantly updated ■ that the technical solutions proposed are reasonable ■ continuity in relations with institutional entities. 4
  5. 5. Some major clients Energy and Utilities Transportation and logistic ICT and Services Finance and Insurance Conglomerate and Industrial Sector 5
  6. 6. SASPI specialisations Consultancy ■ Ordinary current taxationCorporate taxes ■ IAS/IFRS taxation ■ Tax burden estimates, also for reporting purposesCross-Border Tax ■ Analysis of internal tax procedures and compliance with existing legislationVAT and Customs ■ Cross-border taxationTransfer Pricing ■ Tax optimisation in supply chain restructuring projects ■ Tax planning and optimisation for national and international companies and groupsTax Litigation ■ Assistance with extraordinary operations (M&A, restructurings, etc...)Legal and corporate affairs ■ Taxation of financial instruments and transactionsLabour law and consultancy ■ Organisation of family assets (‘family holdings’) and real estate ■ Taxation of non-profit organisations ■ Expatriate taxation ■ Tax due diligence - tax audit Compliance ■ Definition of tax debt, also for reporting purposes ■ Preparation and drafting of annual financial statements ■ Annual tax returns 6
  7. 7. SASPI specialisations Inbound – Foreign investors in Italy ■ Tax advice and alerts on Italian tax developments and newsCorporate taxes ■ Tax feasibility studies and tax review of financial modelsCross-Border Tax ■ Investment structuring (eg, legal forms, PE risk analysis, funding of the investment) ■ Tax due diligence on Italian entities, with a specific focus on international tax issuesVAT and Customs ■ Cash-flow optimization through the analysis and recovery of potential double taxation on,Transfer Pricing amongst others, royalties, interest and dividends ■ Italian entity conversion further to change of business models: eg, commissionaire, limited riskTax Litigation distributor, toll and contract manufacturer, delocalization (unilateral and multilateral APA, new agreements, PE issues, transfer of assets)Legal and corporate affairs ■ Advice and assistance on black-list costs (rulings, agreements and support documentationLabour law and consultancy analysis) Outbund – Italian investments abroad ■ Analysis of foreign tax regimes ■ Investment structuring based on the group business model (legal form, PE risk analysis, funding, relationships with other group entities) ■ 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 ■ Coordination of network and other tax services related to foreign group companies and branches ■ Tax alerts on foreign tax developments and news 7
  8. 8. SASPI specialisations Consultancy ■ Planning VAT and Customs flowsCorporate taxes ■ Maximising VAT deductionsCross-Border Tax ■ Minimising customs costs ■ Analysing the implications of organisational models and contractsVAT and Customs ■ Analysing the customs, tax and commercial policy implications of international exchangesTransfer Pricing ■ Examining the eligibility rules applicable to VAT and customs relief regimes and procedures ■ Assistance in preparing applications and documents to be sent to VAT and customs authoritiesTax Litigation ■ Due diligence for both VAT and customs purposesLegal and corporate affairs ComplianceLabour law and consultancy ■ Direct VAT registrations and VAT representations ■ Domestic and foreign VAT refunds ■ Energy sector compliance ■ Registration tax compliance 8
  9. 9. SASPI specialisations Consultancy ■ Analysis of the supply chains of multinational groups and the related economic relationships toCorporate taxes ensure correct intragroup transfer pricing policiesCross-Border Tax ■ Assistance in structuring transfer pricing policies for new business initiatives, changes to the supply chains within groups for acquisitions or restructurings, also to optimise the overall taxVAT and Customs burden of supply chain restructuring projects ■ Evaluation of the effects of changes in transfer pricing policies and their impact on existingTransfer Pricing proceedingsTax Litigation ■ Assistance and advice on unilateral agreements with the tax authorities (APA) ■ Assistance and advice on drawing up adequate I/C contracts to support pricing policiesLegal and corporate affairsLabour law and consultancy Documentation services ■ Assistance in preparing the ‘Master File’ and ‘Country File’ in line with OECD directives, the European Union Code of Conduct and domestic legislation and procedures ■ Economic analysis, search for comparables using leading databases and verification that the prices applied are appropriate ■ Verification of existing documents and assistance in preparing documentation for the Italian companies of multinational groups ■ Verification of the adequacy of existing documentation in the event of a tax inspection or litigation 9
  10. 10. SASPI specialisations Tax litigation ■ Tax rulingsCorporate taxes ■ Agreements between the taxpayer and the Tax OfficeCross-Border Tax ■ Judicial conciliationVAT and Customs ■ Tax disputes ■ Assistance in criminal tax proceedingsTransfer Pricing ■ Release from seizureTax Litigation ■ Administrative judgements on tax issues ■ Tax refundsLegal and corporate affairs ■ Risk/opportunity assessments on pending proceedingsLabour law and consultancy Areas of reference ■ Customs VAT and duties ■ Business income and related taxes ■ Transfer pricing - Permanent Establishments - Taxation of cross-border transactions ■ Avoidance operations ■ Local taxes; other indirect taxes 10
  11. 11. SASPI specialisations Consultancy ■ Company bylaws and shareholder agreementsCorporate taxes ■ Powers of attorney, contracts with directorsCross-Border Tax ■ Responsibilities of directors/internal bodiesVAT and Customs ■ Company restructuring and reorganisation ■ M&ATransfer Pricing ■ Due diligenceTax Litigation ■ Outsourcing of company secretarial activitiesLegal and corporate affairs ComplianceLabour law and consultancy ■ Legislative Decree 231/01 ■ Privacy ■ Anti-money laundering regulations ■ Relations with supervisory authorities ■ Health and safety in the workplace 11
  12. 12. SASPI specialisations Contracts ■ Purchase and sale, agency, distribution, appointments, brokerage, transportCorporate taxes ■ Lease, rental, loans for useCross-Border Tax ■ Guarantees, suretyships, procurement, establishment of joint ventures ■ Atypical and intra-group contractsVAT and Customs ■ General contract conditionsTransfer PricingTax Litigation Antitrust / Consumer rights ■ National and Community notificationsLegal and corporate affairs ■ Cartels, monopolies and State aidLabour law and consultancy ■ Consumer Code ■ National and Community litigation ■ Misleading advertising Litigation and Arbitration ■ Civil litigation ■ Bankruptcy and insolvency procedures ■ Conciliation, mediation ■ Arbitration and out-of-court resolution of disputes ■ Debt collection 12
  13. 13. SASPI specialisations Labour ■ Company restructuringsCorporate taxes ■ Organisational structures and process analysesCross-Border Tax ■ Management of industrial relations and relations with trade unionsVAT and Customs ■ Organisational, compliance and corporate governance models and legal safety profiles ■ Pay policy and company objectivesTransfer Pricing ■ Company dynamics and labourTax Litigation ■ Social responsibility and codes of ethicsLegal and corporate affairs Labour market and professional trainingLabour law and consultancy ■ Technical and legal assistance to local institutions, public and private employment agencies ■ Public employment office (ordinary, disabled, non-EU) ■ Operator accreditation (criteria and assistance) ■ Bilateral entities: legal assistance (bylaws, financing, relations with institutions and the EU) ■ Inter-professional sources: consultancy, training plans ■ Redundancy funds (CIG and mobilità): assistance and relations with the Ministry and local entities European and cross-border employment relationships ■ Analysis of contracts, secondments, transfers: labour law and social security aspects ■ Legal assistance in managing expatriates ■ Community employment law 13
  14. 14. SASPI specialisations Trade union relations ■ Assistance in relations with trade unions and public entitiesCorporate taxes ■ Renewal and drafting of collective contractsCross-Border Tax ■ Contractual standardizationVAT and Customs PensionsTransfer Pricing ■ Compulsory pensionsTax Litigation ■ Supplementary pensionsLegal and corporate affairs ■ Company welfare plans ■ Basic pension systems, special fundsLabour law and consultancy ■ Contributions, performance, combination of pension contributions over time ■ Pension funds, analysis and drafting of articles of association, operating rules, adjustment of existing funds ■ Supplementary health funds ■ Social responsibility: feasibility studies, processing and project assistance Labour litigation ■ Labour law litigation ■ Assistance both out of court and through all stages of court proceedings, including the Court of Cassation ■ Council of State, European Court of Justice ■ Mapping and completion of prior litigation ■ Out of court resolutions (conciliations, arbitration) and assistance in court 14
  15. 15. Our main offices and contacts Milan Rome Via della Moscova, 3 Largo Chigi, 5 20121 Milan 00187 Rome Phone +39 02.80673.1 Phone +39 06.697757.1 Fax +39 02.89010836 Fax +39 06.69775720 Turin Venice C.so V. Emanuele II, 71 Viale Ancona, 26 10128 Turin 30172 Venice Phone +39 011.50940.1 Phone +39 041.290571.1 Fax +39 011.5094020 Fax +39 041.2905770 E-mail: info@crowehorwath.it Web: www.crowehorwath.it 15

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