Recent and relevant deals in which we are or have been involved include for example:
- Tax optimization for the transfer of family enterprises.
- Assistance for several multinationals in the context of restructuring and mergers.
- Tax advice to a stock exchange listed company concerning the risks of the requalification of income.
- Analyses of the tax regime of capitalization contracts Branch 26.
- Ruling request concerning the split of company groups and losses restructuring.
- Regularization of not reported foreign income.
Recent litigation matters include the following cases:
- We were the only office who filed an appeal before the Constitutional Court against the anti-abuse law. We obtained the annulment of the regularization procedure concerning inheritance taxes and registration taxes.
- We successfully defended the deductibility of management fees between enterprises of an international industrial group.
- In a principle matter concerning the notional interest deduction, we obtained that a multinational doesn’t need to fend the net-active connected to the foreign fixed establishment, from the calculation base of the notional interest deduction.
- As a result of a procedure filed by us, before the Council of State, a local tax on the economic activity was withdrawn because of violation of the principle of equal treatment.
- We obtained annulment of dozens assessments concerning various local taxes.
- We defended a case about tax visits at home for both income taxes as VAT.
- In a VAT dispute we have successfully invoked the annulment of the injunction because of exceeding of the limitation period.
Since 2008, the office annually publishes an “Annual Review of Tax Law Jurisprudence”, which is a compilation of (un)published jurisprudence.