The international cooperation in tax matters to avoid tax avoidance and abuses poses great challenges in the activity of fiscal authorities with audit, inspection and tax assessment more and more specific and devoted to international issues (for example concerning the application of CFC rules, permanent establishment or group taxation).
As to tax proceedings and litigation, we currently cover the following areas of expertise:

• Out-of-court settlements and submission of formal ruling requests to the tax authorities. By means of these legal arrangements, we have been able to reach numerous agreements that have turned out to be very satisfactory for our clients.

• Litigation services. Also in this area, we have a very high success rate, thanks in particular to our risk assessment skills and our ability to build the best line of defence for our clients: this practice area is really one of the excellence spots of our firm. By the way, a number of our professionals have the right of hearing before courts of all levels, all the way up to the Italian Supreme Court, the European Court of Justice and the European Court of Human Rights.