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Dallari Studio Fiscale e Finanziario is a tax boutique firm specialised on tax law, international tax law and financial law.

The Firm

SPECIALISED IN TAX MATTERS

We provide our intellectual activity to the increasingly complex tax matters with vision and simplicity aiming at being excellent in what we do.

We are confident in providing to anyone both the right tax advice and the best tax assistance in front of the Italian Tax Courts simply by utilising our diverse skills, being dynamic and responsible, whilst maintaining the respect for people and a little sense of humour.  For this reasons, we believe all our clients, Italian or international, deserve the greatest of our attention, analysing the tax profiles of any dispute or project, looking for the most suitable solution compliant with current laws and regulations.

We built up a network of independent foreign lawyers located in 25 key business centres around the world who are specialised in tax law.

SKILLS, VISION, RESPONSABILITY AND SIMPLICITY

Expertise

TAX LITIGATION AND TAX ADVICE

Our practice is mainly focused on tax litigation and tax advice on Italian and international taxation for individuals, hnwi, uhnwi, family estates, family offices, corporates and banks, both residents and non-residents.

We analyse the tax treatment of your cross-border, M&A, real estate and financial transactions and also of your family estate planning.

Our method follows the up-to-date, constant and in-depth analysis of legislation, case law, doctrine and general procedures.

We are skilled on estate planning, real estate, M&A, banking and finance, leasing, tax credits, insolvency procedures, shipping and air transport, oil rigs, artists and sportsmen, and expatriates.

Practices

TAX AREAS

Tax litigation

Italian Tax administration make pressure to bring in more tax and to clamp down on avoidance.

We are focused on resolving tax disputes and investigations ranging from advice on information requests to litigation and settlement of tax disputes.

Indeed, we are used to represent both resident and non-resident individuals, banks and companies on tax disputes and litigation in any phase of judgement.

In case of criminal proceedings relating to tax crimes, we provide advice and assistance to crime lawyers in charge of criminal defense in relation to the applicable tax treatment.

  • Tax settlement procedures
  • Tax Administration procedures
  • Arbitration procedures
  • Tax assessments
  • Tax penalities
  • Claims for tax refunds
  • Pre-judicial tax settlements
  • Denial of tax refunds
  • Denial of tax credits
  • Local Tax Courts tax proceedings
  • Supreme Courts tax proceedings
  • Tax rulings
Tax advisory

The Italian tax system is complex and constantly evolving also due to the coordination with the European principles.

Dallari Studio Fiscale e Finanziario analyzes national and international tax laws in addition to the domestic impact of European Court of Justice decisions in the field of taxation, providing tax opinions and tax memo on:

  • Tax structuring for companies and groups
  • Tax planning for Individuals
  • Wealth planning
  • Start-up projects
  • Group renovations
  • Domestic and cross-border investments
  • Domestic and cross-border loans
  • Internationalization projects
  • Debt restructuring
  • Securitization
Estate planning

The ownership and transfer, in life or in event of death, of family properties always generate relevant tax issues that must be evaluated carefully and, when possible, by time.

Based on your needs and wishes, we help you in efficiently organizing your estates, either in Italy or abroad, including generational handover and turn-around transactions, analyzing both domestic and international tax issues.

We are skilled on:

  • Italian properties
  • International estates
  • Financial instruments
  • Life insurances
  • Shareholdings
  • Artworks and Fine Arts
  • Classic cars
  • Yachts and aircrafts
  • Inheritances / estates
  • Gifts
  • Properties transfers
  • Business transfers
  • Generational handover
  • Voluntary disclosure
  • Resident and non-resident owners
  • Trusts
International taxation

The Firm may provide advice and assistance, including tax opinions, on tax issues relating to international tax issues, such as:

  • Tax residence
  • Tax treaties
  • European taxation and Directives
  • Impact on domestic taxation as a result of ECJ tax decisions
  • Inbound and outbound investments
  • Cross-border financing
  • Cross-border leasing transactions
  • Digital economy taxation
  • Controlled Foreign Companies rules
  • Transfer pricing
  • Permanent establishments
  • E-commerce
  • Expatriates
  • Artists and sportsmen
  • Italian tax monitoring (RW)
  • Voluntary disclosure procedures
  • Brexit tax issues
M&A taxation

Dallari Studio Fiscale e Finanziario is active on designing and realising M&A transactions and reorganisations providing assistance in case of:

  • Structures for the acquisition
  • Appraisals and evaluations
  • Deed of transfer
  • Flows of funds
  • Tax due diligence
  • Tax credits
  • Mergers and demergers
  • Share deals
  • Business transfer
  • Contributions
  • Transformations
  • Tax credits deals
Real Estate taxation

Dallari Studio Fiscale e Finanziario is skilled in every area of real estate taxation, mainly focusing on:

  • Real estate transfers
  • Constructions
  • Financial lease
  • Real estate investment entities
  • Italian investments in foreign properties
  • Foreign investments in Italian properties
  • Real estate investment funds / sgr / investors
  • Real estate income
  • Annuities
  • Maintenance and restoration
  • Real estate tax credits
  • Bonus 50%
  • Ecobonus 65%
  • Ecobonus 110%
Corporate taxation

Dallari Studio Fiscale e Finanziario may assist resident and non-resident companies and banks on the analysis of the Italian tax treatment both for ordinary and extraordinary activities.

The Firm also advices companies, banks and insurance companies, which are subject either to IAS/IFRS or to Italian GAAP, for their financial statement’s accountancy issues.

  • Financial Statement
  • Italian GAAP
  • IAS / IFRS
  • Dividends
  • Interests
  • Royalties
  • Business Income
  • VAT
  • Tax credits (due diligence, certifications, refund procedures)
  • Tax losses
  • Digital economy taxation
Capital market taxation

The Firm may provide advice on financial transactions carried out by individuals, entrepreneurs, companies, and banks.

We provide advice to:

  • Both the lender and the borrower, in financial transactions
  • Both the lessor and the lessee, in leasing transactions
  • Both the companies and the management, in MBO transactions
  • Private equity deals
  • Venture capital deals
  • Securitizations
  • Listings
  • Tax credits
Transfer Pricing

The Firm, with respect to intercompany transactions, may provide assistance for the development of transfer pricing analysis and policies as provided by OECD methodologies at arm’s length and in compliance with the Italian legislation.

  • Structuring
  • Determination of the arm’s length value
  • Traditional methods
  • Alternative methods
  • Arrangement of documents Coordination of economic analysis
Indirect taxation

We are skilled on VAT, stamp duty, mortgage and land registry taxes, as well as in the field of the municipal taxes (ICI, IMU and environmental taxes).

The Firm provides assistance during the assessment procedures of these taxes as well as in every phase of relating tax litigation.

Industries

EXPERIENCE

We have a strong experience in the following industries

  • Non residents
  • Families wealth/estate
  • Expatriates
  • Artworks / Fine Arts
  • Leisure
  • Insolvency procedures
  • Oil platforms
  • Tiles
  • Aquaculture
  • Manifacturing
  • Real estate
  • Automatic machinery
  • Automotive
  • Fashion
  • Food and beverage
  • Textile
  • Private equity
  • M&A
  • Tax credits
  • Trasports
  • Chemical & Pharmaceutical
  • Financial
  • Leasing
  • NPL
  • Venture capital
  • Energy
  • Technology

Gian Marco Dallari

Dottore Commercialista, ADV. LLM.

Gian Marco is an Italian Dottore Commercialista specialised in tax law and international tax law, focused on tax advice and tax litigation.

During his career, he advised resident and non-resident clients from many industries on M&A structuring, tax due diligence, real estate and financial transactions. He has also experience in wealth and estate planning, transfer pricing policies, insolvency procedures, shipping and air transports, oil platforms, art, stock options plans and expatriates.

Following the M.Sc. in Economics from Bologna University in 2001, Gian Marco received the Master in Corporate and International Taxation from Ipsoa Business School (Milan), and the Master of Law Advanced (Adv. LL.M.) in International Tax Law from the International Tax Centre ITC – Law Faculty, Leiden University (the Netherlands).

Gian Marco is also a chartered accountant, Italian native and fluent in English.

Network

SPECIALISED TAX PROFESSIONAL

As a result of the combination of our international relationships with foreign lawyers and professionals focused on tax law, in 25 key business centres around the world, and our expertise on Italian, European and international taxation, we may assist:

  • Italian clients on foreign transactions, cross-border transactions, internationalization projects and foreign investments;

  • Non-resident clients on cross-border transactions involving Italy and their projects of Italian investments analysing both Italian and international tax treatment;

  • Permanent establishments of foreign entities/foreign clients/Italian multinational which may require an Italian tax adviser supervising their global transactions/structures.