Crowe Horwath - Studio Associato Servizi Professionali Integrati is a leading Italian professional services firm with over 130 professionals across offices in Milan, Rome, Turin, and Venice. The firm provides legal, tax, and labor law consulting services with specializations in corporate taxes, cross-border tax, VAT and customs, transfer pricing, tax litigation, legal and corporate affairs, and labor law. As a member of the Crowe Horwath International network, the firm collaborates with other professionals to offer clients high-level integrated services.

1. Profile: Studio Associato Servizi Professionali Integrati
Last update: April 2012

2. The Firm
Crowe Horwath - Studio Associato Servizi Professionali Integrati is a leading Italian professional services firm offering legal, tax and
labour 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 partner
of 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, also
through an important partnership with the team of labour law experts coordinated by Prof. Tiziano Treu and Prof. Angelo Pandolfo.
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3. Membership of Crowe Horwath International
Crowe Horwath International, one of the top 10 global accounting firms, is an international Network with 167 independent accounting
and advisory services firms, 650 offices and more than 28,000 professionals and staff in 109 countries around the world.
Crowe Horwath International's member firms are committed to impeccable quality service, highly integrated service delivery processes
and 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 its
professionals, supports clients undertaking new ventures or expanding into other countries.
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4. Value added services
The Firm's strategy is to focus on the highest-standard specialisations in the different areas of law, whilst maintaining an
interdisciplinary spirit of teamwork amongst its professionals. This approach enables us to provide clients with timely responses
aimed 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 to
ensuring:
■ that the firm’s professionals are constantly updated
■ that the technical solutions proposed are reasonable
■ continuity in relations with institutional entities.
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5. Some major clients
Energy and Utilities Transportation and logistic
ICT and Services
Finance and Insurance
Conglomerate and Industrial Sector
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6. SASPI specialisations
Consultancy
■ Ordinary current taxation
Corporate taxes ■ IAS/IFRS taxation
■ Tax burden estimates, also for reporting purposes
Cross-Border Tax
■ Analysis of internal tax procedures and compliance with existing legislation
VAT and Customs ■ Cross-border taxation
Transfer Pricing ■ Tax optimisation in supply chain restructuring projects
■ Tax planning and optimisation for national and international companies and groups
Tax Litigation
■ Assistance with extraordinary operations (M&A, restructurings, etc...)
Legal and corporate affairs ■ Taxation of financial instruments and transactions
Labour 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
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7. SASPI specialisations
Inbound – Foreign investors in Italy
■ Tax advice and alerts on Italian tax developments and news
Corporate taxes ■ Tax feasibility studies and tax review of financial models
Cross-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 issues
VAT 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 risk
Tax 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 documentation
Labour 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
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8. SASPI specialisations
Consultancy
■ Planning VAT and Customs flows
Corporate taxes ■ Maximising VAT deductions
Cross-Border Tax ■ Minimising customs costs
■ Analysing the implications of organisational models and contracts
VAT and Customs
■ Analysing the customs, tax and commercial policy implications of international exchanges
Transfer 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 authorities
Tax Litigation
■ Due diligence for both VAT and customs purposes
Legal and corporate affairs
Compliance
Labour law and consultancy
■ Direct VAT registrations and VAT representations
■ Domestic and foreign VAT refunds
■ Energy sector compliance
■ Registration tax compliance
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9. SASPI specialisations
Consultancy
■ Analysis of the supply chains of multinational groups and the related economic relationships to
Corporate taxes ensure correct intragroup transfer pricing policies
Cross-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 tax
VAT and Customs burden of supply chain restructuring projects
■ Evaluation of the effects of changes in transfer pricing policies and their impact on existing
Transfer Pricing proceedings
Tax 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 policies
Legal and corporate affairs
Labour 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
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10. SASPI specialisations
Tax litigation
■ Tax rulings
Corporate taxes ■ Agreements between the taxpayer and the Tax Office
Cross-Border Tax ■ Judicial conciliation
VAT and Customs
■ Tax disputes
■ Assistance in criminal tax proceedings
Transfer Pricing
■ Release from seizure
Tax Litigation ■ Administrative judgements on tax issues
■ Tax refunds
Legal and corporate affairs ■ Risk/opportunity assessments on pending proceedings
Labour 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
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11. SASPI specialisations
Consultancy
■ Company bylaws and shareholder agreements
Corporate taxes ■ Powers of attorney, contracts with directors
Cross-Border Tax ■ Responsibilities of directors/internal bodies
VAT and Customs
■ Company restructuring and reorganisation
■ M&A
Transfer Pricing
■ Due diligence
Tax Litigation ■ Outsourcing of company secretarial activities
Legal and corporate affairs Compliance
Labour law and consultancy ■ Legislative Decree 231/01
■ Privacy
■ Anti-money laundering regulations
■ Relations with supervisory authorities
■ Health and safety in the workplace
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12. SASPI specialisations
Contracts
■ Purchase and sale, agency, distribution, appointments, brokerage, transport
Corporate taxes ■ Lease, rental, loans for use
Cross-Border Tax ■ Guarantees, suretyships, procurement, establishment of joint ventures
■ Atypical and intra-group contracts
VAT and Customs
■ General contract conditions
Transfer Pricing
Tax Litigation
Antitrust / Consumer rights
■ National and Community notifications
Legal and corporate affairs
■ Cartels, monopolies and State aid
Labour 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
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13. SASPI specialisations
Labour
■ Company restructurings
Corporate taxes ■ Organisational structures and process analyses
Cross-Border Tax ■ Management of industrial relations and relations with trade unions
VAT and Customs
■ Organisational, compliance and corporate governance models and legal safety profiles
■ Pay policy and company objectives
Transfer Pricing
■ Company dynamics and labour
Tax Litigation ■ Social responsibility and codes of ethics
Legal and corporate affairs
Labour market and professional training
Labour 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
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14. SASPI specialisations
Trade union relations
■ Assistance in relations with trade unions and public entities
Corporate taxes ■ Renewal and drafting of collective contracts
Cross-Border Tax ■ Contractual standardization
VAT and Customs Pensions
Transfer Pricing
■ Compulsory pensions
Tax Litigation ■ Supplementary pensions
Legal and corporate affairs ■ Company welfare plans
■ Basic pension systems, special funds
Labour 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
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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
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