Tax activity

BGR adopts a matrix structure for business lines and taxes to better respond to increasingly complex and sector-specific regulations that require new specialisations. Teamwork and discussion among professionals foster the necessary dialogue to assess different tax issues comprehensively and critically.

This working methodology enables the Firm to assist the client even in the most complex situations by providing qualified teams capable of proposing integrated solutions with an overall vision.

The Firm’s lawyers and accountants help clients solve various problems both at a consultancy level and in dialogue with the Italian tax authorities.

Corporate taxation

BGR employs professionals with specialist skills who cover all aspects of company taxation, guiding businesses through the various stages of their life, starting from incorporation.

With its team of lawyers and chartered accountants, the Firm offers its clients highly qualified tax consulting services.

Our direct tax, VAT and indirect tax experts assist our clients in all aspects of everyday business life, supporting them in the fulfilment of tax liabilities and for extraordinary events, such as extraordinary transactions, international tax services, assistance and representation in relations with the Italian tax authorities and in litigation, filing of tax rulings, issuance of written opinions, including pro-veritate ones.

BGR also offers its clients continuous tax information, including periodic update circulars and personalised training through webinars, courses and conferences.

Patent box

Following in the footsteps of other EU member states, the Patent Box regime was introduced in Italy in 2015. The aim was to increase the attractiveness of the Italian market and encourage investment in research and development. 

Regarding the criteria and methods used to determine taxable income, administrative practice refers to the international standards developed within the OECD on Transfer Pricing.

With its many years of experience in this field, the Firm combines in-depth knowledge of the regulations with the business skills necessary for a proper and demonstrable process of defining income eligible for tax relief. Since the introduction of the regime, it has worked alongside companies owning intangible assets to quantify Patent Box income, both during disputes with the Revenue Agency and for self-assessment.

International taxation and transfer pricing

The Firm also works with its leading affiliates in the most important countries worldwide to provide consulting on international taxation, from the taxation of cross-border income – in accordance with international treaties and European directives – to the rules applicable to permanent establishments and CFCs. 

BGR assists multinational groups in the entire process of defining, implementing, documenting and upholding transfer pricing policies.

  • It supports them upstream in defining the dynamics of intragroup flows and the applicable transfer pricing policies, as well as in preparing the related supporting contracts,
  • and downstream, in the event of disputes or litigation with the tax authorities. 

 

The Firm also has extensive experience in:

  • Advance Pricing Agreements (APA), set up to define in advance – on a consultative basis with the tax authorities – the methods applicable for determining transfer prices;
  • Mutual Agreement Procedures (MAP), that is, international dispute resolution instruments aimed at eliminating potential double taxation arising from domestic or international transfer pricing disputes.

Tax litigation and relations with tax authorities

The Firm assists clients in their dealings with tax authorities and auditing bodies, offering highly qualified advice, strategic management of procedures and assistance in the various related tasks. In particular, the Firm’s team of specially trained and experienced professionals enables it to provide:

  • preventive advice on possible audit and assessment risks, as well as on the entitlement to any tax refunds;
  • assistance and representation in all appeal procedures of the Italian tax authorities;
  • ongoing assistance during tax audits regarding the scope of possible subsequent disputes;
  • assistance and representation in refund, self-assessment, prior consultation and tax agreement procedures, with a particular focus on the impact on the taxpayer’s business and possible consequences in terms of tax litigation;
  • defence before all Tax Commissions and the Court of Cassation in appeals against taxation measures, collections, refund refusals and more generally in all acts and proceedings under the law.

Individual taxation

BGR can offer consultancy services to help individuals manage their personal tax affairs and support them to comply with the requisites of the law.

The Firm also has proven experience in the management, from a taxation and declaration point of view, of movable and immovable assets held in Italy and abroad by individuals. It also provides assistance and advice on tax planning and optimisation of asset management.

BGR can help companies manage expatriation policies or implement employee incentive systems such as share plans, stock option plans, and, more generally, tax-optimised remuneration policies.

Finally, BGR uses its corporate and family wealth experts to assist clients in generational transition planning.