Europe
European Tax & Legal Services
Holding structures, advanced tax planning, funds and wealth planning for entrepreneurs, families and investors across Italy, Luxembourg and the United Kingdom.
Italy
Italian Tax Law & Advisory
Comprehensive assistance for entrepreneurs, companies and private individuals: from day-to-day tax planning to tax litigation management, extraordinary transactions and cross-border taxation.
Tax Litigation & Defense
Professional assistance at every stage of tax disputes in Italy, from the initial audit through to appeals before the Tax Courts.
Challenge of income tax assessments, wealth indicators and ISA sector studies before the Italian Tax Courts of Justice.
Support during inspections by the Italian Revenue Agency and the Tax Police: liaison with auditors and protection of taxpayer rights throughout the process.
Negotiation and discounted settlement of tax assessments to reduce penalties and interest through the accertamento con adesione procedure.
Mandatory pre-litigation procedure for assessments up to EUR 50,000: assistance in reaching an agreement with the tax authority before formal proceedings begin.
Advanced Tax Planning
Structured tax strategies for entrepreneurs and companies: optimisation of the overall tax burden in full compliance with Italian and international tax law.
Analysis and optimisation of the corporate and personal tax structure, including choice of the most efficient legal form for the business.
Structuring the optimal mix of salaries, dividends and benefits to reduce the overall effective tax rate for owner-managers.
Establishment and management of Italian holding companies to optimise the ownership of shareholdings, real estate and financial assets.
Application of double tax treaties, tax residence analysis, CFC rules and planning for multinational groups with an Italian nexus.
Extraordinary Transactions
Tax and legal support for major corporate reorganisations: from due diligence to transaction structuring and post-closing compliance.
Contributions of business units and shareholdings: tax analysis, transaction structuring and notarial assistance.
Full tax assistance for merger and demerger transactions, both proportional and non-proportional, including cross-border EU operations.
Tax planning for capital gains on share disposals, participation exemption (PEX), step-up regimes and transaction structuring.
Group restructurings, corporate conversions, liquidations and generational transfers with full tax optimisation.
Luxembourg
Holding Structures, Funds & Wealth Planning
Luxembourg is Europe’s leading hub for international holding companies, investment funds and private wealth planning for entrepreneurial families and HNWIs. We provide full structuring services with coordination of leading local private banks.
European Holding Structures
Luxembourg offers Europe’s most favourable regime for holding international participations, with full exemption on dividends and capital gains under the participation exemption.
Societe de Participations Financieres: the standard Luxembourg holding vehicle, with access to the full treaty network and EU Parent-Subsidiary and Interest & Royalties Directives.
Vehicle dedicated to private family wealth management: full income tax exemption on dividends, interest and capital gains from private participations.
Design of multi-jurisdictional holding chains with Luxembourg as the central hub to optimise intra-group cash flows and reduce withholding tax leakage.
Structuring of profit distribution flows and exit planning to minimise the overall tax cost across all jurisdictions involved.
Private Equity & Investment Funds
Luxembourg is Europe’s leading platform for alternative investment funds. We structure both regulated and unregulated vehicles for institutional and private investors.
Establishment of RAIF (Reserved Alternative Investment Fund), SIF (Specialised Investment Fund) and SCSp (limited partnership) for PE, real estate and credit strategies.
Structuring with authorised alternative investment managers (AIFM) in Luxembourg or other EU jurisdictions, with EU passport for cross-border distribution.
Dedicated vehicles for real estate co-investments: SCSp or SA structures with flexible governance and optimisation of real estate capital gains taxation.
HNWI Wealth Planning
Structured wealth solutions for entrepreneurial families and high-net-worth individuals: asset protection, succession planning and private banking coordination.
Design of SPF or family foundation structures for the management and cross-generational protection of private wealth.
Integration of the holding structure with leading private banking institutions (Pictet, Lombard Odier, BIL, ING Luxembourg) for fully coordinated wealth management.
United Kingdom
UK Company Structures, Tax Residence & E-commerce
The United Kingdom offers a flexible and competitive tax system for international groups, digital businesses and professionals. We assist Italian clients in establishing UK vehicles and managing British tax residence.
UK Ltd for International Groups
The English private limited company is a versatile vehicle for intermediate holdings, operational sub-holdings and international structures that benefit from the UK’s extensive treaty network.
Rapid incorporation of a private limited company, registration at Companies House, bank account opening and initial compliance obligations.
Optimal structuring of profit distributions from the UK Ltd to Italian or international shareholders, with application of the relevant double tax treaty provisions.
Analysis of the place of effective management to avoid dual corporate tax residence and ensure the correct allocation of taxing rights between jurisdictions.
UK Tax Residence
UK individual tax residence is determined by the Statutory Residence Test: a precise set of rules that establish whether and when an individual is tax resident in the United Kingdom.
Detailed analysis of days spent in the UK, connecting factors (work, family, accommodation) and determination of resident or non-resident status for each tax year.
Planning for non-UK domiciled individuals: application of the remittance basis for foreign income and gains where the regime remains available and beneficial.
Structuring of departure from the UK: exit tax analysis, transfer of tax residence to Italy and assessment of the Italian inpatriate regime or flat tax regime.
E-commerce & International Trading
UK structures for digital businesses and international trading: tax optimisation, cross-border VAT management and coordination with post-Brexit customs rules.
Incorporation of Ltd companies for e-commerce, SaaS and digital marketplaces: permanent establishment risk analysis and optimisation of the 25% corporation tax rate.
UK VAT registration, post-Brexit compliance for sales into the EU, OSS/IOSS regimes and structuring of supply chains to avoid double VAT exposure.
Ready to structure your European presence?
Our European tax experts are ready to analyse your situation and propose the most efficient structure for your needs.
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