Tremonti Romagnoli Piccardi E Associati

The firm:Tremonti Romagnoli Piccardi e Associati was established in the early ’80s by Giulio Tremonti – the former Italian Minister of Economy and Finance – under the name Studio Tremonti e Associati. Since its inception, the firm has been growing steadily to reach its current size of approximately 40 professionals working between its Milan and Rome offices. For more than 30 years, the firm has been providing a full range of tax advice and related services to domestic and international clients on the main corporate, industrial and financial transactions carried out in the Italian market. The firm’s professionals are particularly experienced and skilled in a number of tax areas including corporate and M&A, reorganisation, private equity, banking and finance, securitisations, structured finance, NPL, debt restructuring, real estate, VAT, Patent Box and transfer pricing. The firm also provides ongoing advice and assistance to clients during the course of tax audits, tax litigation and settlement proceedings with the Italian Revenue Agency; defending clients in proceedings before the tax courts at all levels of jurisdiction.

Areas of practice
M&A and capital markets: The firm assists clients in strategic tax planning and in carrying out a very diverse range of extraordinary transactions, from private equity and leveraged buy-outs, to reorganisations of both domestic and international groups. The firm’s professionals also have ample experience in listings on the stock exchange, initial public offerings, and swaps, mergers, de-mergers and liquidations.

Corporate and group taxation: The professionals provide strategic planning advice to corporate groups and assist clients in availing of tax incentives and cooperative compliance programs. The firm provides all types of tax opinions and secures tax rulings and technical advice from the Italian Revenue Agency.

Taxation of financial instruments: The firm advises banks, financial institutions and investment funds in relation to Italian and international financial transactions, handling the drafting and negotiation of multilateral financial agreements (including high yield bonds) and the drafting of legal opinions concerning structured finance, non-performing loans and capital market transactions.

International taxation: The firm advises its clients on the application of European regulations, double taxation conventions and Italian rules applicable to international operations, whilst having constant regard to the ever-changing interpretative developments at both the EU and the OECD level. The firm regularly assists clients on transfer pricing and multi-jurisdictional tax controversies, including MAPs. Moreover, thanks to the support of its international network, the firm is also able to guide its clients in their international activities, with a special focus on cross-border mergers and acquisitions, joint ventures, spin-offs, business restructuring, cross-border financing and structured finance products.

Transfer pricing: The dedicated transfer pricing team has gained vast experience in international procedures, such as Advance Pricing Agreements (APA) and Mutual Agreement Procedures (MAP) both in Italy and abroad. The firm advises clients on transfer pricing, assisting both in the design of their TP policy and in the negotiation and conclusion of international procedures. The firm also regularly gives assistance on transfer pricing litigation and pre-litigation matters.

Real estate: The firm works with the main operators in the domestic and international real estate markets regarding acquisitions, leasings, financings, divestitures, sale-leasebacks and also provides tax advice concerning transactions concluded on regulated markets by means of closed real estate funds set up under Italian law.

Tax litigation and tax rulings: The firm is fully experienced in working with the Tax Authorities and in assisting clients during domestic and international tax litigation. The professionals specialise in matters related to direct taxes, VAT, registration tax, international taxation, transfer pricing and local taxes, assisting clients during the tax audit phase and throughout extra-judicial and all other types of pre-litigation procedures. The expert team of lawyers is skilled in providing assistance in litigation proceedings before the Tax Courts, the Supreme Court, and the European Courts. The team also assists clients in the filing of all types of requests with the Italian Revenue Agency, including applications for international rulings and requests for new investments.

Taxation of individuals: The firm advises individuals on estate and inheritance tax planning and asset protection (eg corporate structures, family agreements, trusts, foundations, etc). The firm also advises corporations and their executives on all aspects of planning and implementation of incentive plans, stock option plans and welfare aziendale, as well as qualified stock options.

VAT, indirect and local taxes: The firm provides assistance to clients in relation to VAT matters both in terms of standard business operations and in the most complex domestic and international transactions (eg by means of VAT grouping or consortium company structures within the banking sector). The firm’s professionals are also experienced in the areas of registration tax and other indirect taxes, providing consultancy in relation to the main recurring and non-recurring issues.

International work: A large part of the activity of the firm involves international clients and cross-border operations.  Over the years, the firm has built up a network of high-profile law firms and tax firms in the main European and non-European jurisdictions. These relationships allow the firm to provide its clients with complete assistance and advice in the global market. The main focus of the firm’s international work is, among others, on cross-border mergers and acquisitions (both inbound and outbound), initial public offerings and other exit strategies, as well as in structuring financial products, Pan-European private equity, venture capital, other closed-end funds, cross-border financing transactions and securitisations.