Facchini Rossi Michelutti Studio Legale Tributario

Facchini Rossi Michelutti is an Italian independent law firm specialised in tax law. Over the years the firm has been recognised as a leading firm in the taxation field, with specific focus on M&A transactions and the private equity sector. The firm provides any type of services in the areas of tax in Italy, including assistance in M&A transactions, tax litigation, corporate tax, VAT and other indirect taxes, international tax, taxation of financial instruments, real estate taxation, transfer pricing, patent box, private clients and tax compliance. With offices in Milan and Rome, the firm has around 40 professionals (partners, managing associates, senior associates, associates and trainees) fully dedicated to international and domestic tax matters.

Main areas of practice:
■ Tax advice
■ Tax on M&A
■ Tax litigation

FRM provides a full range of services which include tax consultancy services, international taxation, transfer pricing, assistance in tax litigation as well as pre-litigation phases and in ruling procedures with the Italian tax authorities.

Corporate tax: In the field of corporate taxation, FRM provides a comprehensive range of consultancy services to meet the needs of all sorts of companies and transactions (such as business restructurings, M&A deals, tax optimisation schemes, securitisations), including any related cross-border tax implications. In particular, FRM provides consultancy services for multinationals, banking and financial institutions. Specific expertise has been developed with reference to the taxation of sophisticated financial products and to the tax aspects of the application of the International accounting standards IAS/IFRS.

Management incentive plans: The firm provides consultancy services in the field of management incentive plans/carried interest schemes for employees/directors of corporations and investment funds.

International taxation: The firm provides advice on any type of international tax matters, including the application of tax treaties, international tax planning for multinational groups, international tax rulings and transfer pricing issues. FRM’s services also cover issues relating to State Aid and the application of fundamental freedoms guaranteed by the Treaty on the Functioning of the European Union.

Taxation of individual and estate planning: The firm works extensively with high net worth individuals and families with respect to transfers of residence (inbound and outbound) and generational tax planning. The professionals have a specific expertise in all tax aspects relating to the settlement and unwinding of trusts, financial and insurance products, and ownership of ships and aircrafts.

Private equity funds: Since its foundation FRM has gained an extensive experience in dealings with private equity funds and is now a leading tax firm as far as LBO transactions are concerned. In particular, FRM assists both foreign and domestic private equity funds and has a strong reputation and knowledge on all tax issues connected to the structuring of complex financing transactions. FRM provides also backup activities in the context of LBO transactions, including activities of tax due diligence.

Tax litigation: The firm provides assistance at all stages of tax litigation and pre-litigation. FRM draws up defenses arising out of tax audits and represents companies and individuals before tax courts, the Italian Supreme Court of Cassation The firm gained particular experience in the management of the pre-litigation phases with the Italian tax authorities in order to achieve settlement of complex tax matters. The experience of the firm also covers dealing with criminal tax matters, arising in the context of tax audits and tax assessments, in collaboration with well-reputed criminal lawyers.