Tax litigation and deflationary instruments

The Firm offers assistance to the client to prevent disputes from arising in the event of tax audits, and during the course of the checks, and, finally, at the conclusion of the checks themselves. In particular, the professionals of the firm identify the best strategies for managing disputes, both through the so-called deflationary tools for litigation (self-protection, acquiescence, assessment with acceptance and complaint) and through the filing of tax appeals to the competent commissions.

Particular experience has been acquired in the preparation and presentation of requests for rulings concerning tax issues for which there is interpretative uncertainty, or of a qualifying nature, or, finally, aimed at accessing particular regimes or the non-application of penalising regulations (shell companies, company with systematic loss, controlled foreign companies); the ruling is aimed at obtaining a specific binding opinion from the Financial Administration and which protects the client from subsequent disputes.