PG&Partners’ long-standing expertise in international tax consultancy dedicated to international clients and especially to industrial clients with German origin integrated its tax practice and added to the comprehensive range of legal services offered by R&P Legal ( https://replegal.it/en/ ). R&P Legal is a large and well-established Italian law firm founded 70 years ago in Torino and with its main office in Milan, Italy.
The entire team of PG&Partners Milano guided by Marco Petrucci, who is both, lawyer and tax consultant, with competences in Transfer Pricing, M&A, assistance with Fiscal Inspections and Fiscal disputes as well as general tax consultancy, combined their respective strengths and join the professionals of R&P Legal. With offices in a total of seven Italian cities and a newly combined team of more than 190 professionals, this new partnership will help provide a more comprehensive range of legal and tax services. Thanks to this integration, Marco Petrucci and Enrico Bressan became partners of R&P Legal.
Drawing up of By-laws and of special shareholders’ agreements. Transactions aimed at increasing or decreasing the share capital, and at changing the corporate structure. Management of company pre-winding up and winding up phases up to the respective striking off from the Companies Register. Liability actions against directors and statutory auditors. Litigation between shareholders and the company, and between the company and the directors. We have developed special expertise also by holding the office as liquidators in large corporate winding up procedures.
Drawing up of contracts for hiring executives and Supplementary Corporate Agreements. Management of staff reduction and collective dismissal procedures. Defending the company in employment litigation, as well as liability litigation for danno biologico arising out of the working activity
Startups and Scaleups coaching and support to fundraising process; design and development of package to be used to present the business case to professional investors (from investment readiness assessment to business plan, Company evaluation, financial roadmap and communication to prospect investors); admin financial services “CFO-like”, i.e. enhancement of management control system, reporting, cash-flow analysis and ratios; Term Sheet analysis and support to Due Diligence preparation and execution phases; Business Intelligence and network facilitation to search for investors.
Company and shareholding valuations. Corporate, tax and financial due diligence. Assistance in negotiations and formulation of share transfer, contribution, merger or spin-off transactions. Drawing up of the relevant agreements between the parties and of the deeds of the companies involved.
We become our clients’ partners by offering them the possibility to both outsource the administrative and accounting functions, including the management of collections, payments and debt collections, and to avail themselves of thorough ongoing legal support. That is the equivalent of placing the functions of their accounting department and their tax and legal affairs within our offices, remaining remotely connected to their data remotely, thus also allowing less structured companies to avail themselves of specialised and constantly up-to-date professionals, with a reasonable fixed cost and without having to worry about managing either recruiting or turnover.
Assistance during all tax inspections. Assistance in collecting the Tax Assessment Report and drawing up of the relevant Taxpayer’s Remarks. Negotiations with the Inland Revenue during the Tax Settlement Proposal phase. Defence before the Provincial and Regional Tax Courts and before the Court of Cassation. Preventive activities in view of protecting directors from the risks of incurring criminal liability.
VAT application to cross-border distribution flows, sale transactions and delivery in different countries (VAT triangulations), VAT application to special transactions, carousel fraud prevention, VAT credit certification, management of VAT refunds and VAT litigation
Functional and “value chain” analysis, choice of the transfer pricing method and calculation. Drafting of the transfer pricing National Documentation, Master File and Country File. Assistance during all tax inspections and management of the relevant tax litigation. Out-of-court procedures foreseen by the Double Tax Treaties in view of obtaining the so-called “secondary adjustment” abroad (MAP – Mutual Agreement Procedures). International Questioning for three-year agreements with the Inland Revenue (APA – Advanced Prices Agreements). Examination of the risks of existence of a permanent establishment following the new BEP 7 and the amendments brought about by article 162 of the Income Tax Consolidation Act (“TUIR”). Opening of permanent establishments and formulation of the taxable income allocation system between foreign countries and Italy.
Since 2004, we have been giving assistance to companies in applying both Double Tax Treaties and EU laws and regulations, thus being involved in complex cross-border transactions, in structuring dividend, interest and royalty flows, as well as in specific Italian tax and VAT issues. We have developed in-depth expertise in transfer pricing, in permanent establishments and in the relevant tax litigation.