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Partners contact

Corporate Tax Governance
Guido Arie Petraroli

Patrizio Braccioni

Despite appearances, the tax regulation framework has changed dramatically in the past four years. At the international level, the BEPS
initiative has been launched, while the European Union has issued, and the Member States have implemented, several directives on
administrative cooperation.
These directives require an exchange of data and information on almost all international relationships. FATCA and the CRS (Common Reporting
Standard) have also been implemented. In order of time, DAC6 is also being implemented in Italy (European Delegation Law 2018, approved in
October 2019). It includes disclosure obligations for tax planning operations deemed aggressive, amongst other things. In Italy, the entry into force
in 2019 of the insolvency and business crisis code, with the related extension of audit obligations and the establishment of robust organisational
and accounting structures, as well as the inclusion of tax offences in Legislative Decree 231/01, have happened in the recent past. As a result,
companies have also been reflecting on the effectiveness of their tax management and tax risk control systems, a variable that should no longer
be neglected and that now goes beyond traditionally more bureaucratic aspects.
The cooperative compliance regime, for those entitled to access it, or the establishment of suitable tax risk oversight, has become a significant
aspect of corporate governance: tax governance has become an important part of the broader corporate governance picture.
LED Taxand can assist companies on this necessarily evolving path of internal control systems aimed at preventing or reducing tax risk, a
path which, in addition to requiring a high level of professionalism in tax matters, also presupposes knowledge of the most important corporate
governance rules and internal control systems.

Partners contact
Tax Disputes
Carlo Polito
Guido Arie Petraroli

With tax administrations around the globe becoming increasingly disputatious, exposure to global task risk is greater than ever.
We will be there to support you through the challenges of a tax audit or controversy, through to the litigation stage (if necessary), ensuring the most
thorough and strategically sound advice.
We deliver a range of tax disputes resolution services with a global focus:
• Managing relationships with the tax authorities;
• Advising on Courts´ Case Law development and Tax Administration position in each jurisdiction;
• Defining your best strategy to cope with multiple jurisdictions Tax Audits;
• Tax audit and controversy support in domestic and international tax issues, such as alleged PE in Italy and VAT frauds;
• Defending your tax position before the courts;
• ECJ disputes resolution.

Partners contact

TP & Business Restructuring
Francesco Cardone Stefano Bognandi

Alfredo Fossati

Our team of dedicated experts work as an integrated team to help you approach TP and business restructuring arrangements to meet
commercial and operational needs.
It’s more than just risk management. You might need to adapt your pricing policies to meet legal and economic requirements. Or restructure to
improve efficiencies and drive business performance. Whatever your approach, we’ll guide you to the most logical arrangement.
LED Taxand has a multidisciplinary team of highly competent and qualified professionals in different areas of intervention. Our Firm, in connection
with Taxand, is able to provide coordination for implementation of measures targeted at the same time in different tax jurisdictions. The range of
services offered include:
• analysis of the business model, definition of transfer pricing policies and corporate restructuring;
• company evaluations and intangible assets;
• assessments on arm’s length royalty rates;
• assistance during tax audits;
• negotiation of mutual agreements and arbitration procedures;
• negotiation of advance pricing agreements;
• IP planning and structuring;
• assistance with Patent Box regime;
• benchmark analysis for any type of transaction (goods, services and financing);
• preparation of the documentation on transfer pricing both locally and globally.

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