international tax


Studio Sfondrini’s expertise lies in international tax matters acquired during years of practice in Italy and abroad. The firm advises international clients about the best structures to adopt for their foreign investments.

Matters that are specifically dealt with are

• Application of special tax domestic regimes (e.g. Italian participation exemption and group relief)
• Group structuring and taxation of cross border transactions
• Application and interpretation of tax treaties
• Permanent establishment issues
• International tax rulings, in particular according to Italian legislation
• Tax issues in relation to employee secondment


Within Studio Sfondrini a particular emphasis is given to transfer pricing issues where cost efficient services are provided which comply with Italian and OECD rules.

In particular:

• Functional and risk analysis
• Comparability analysis
• Italian and European Benchmarking Analysis for identification of the comparables;
• Drafting of the Master file and (or) of the Country Specific documentation as provided by the EU Code of Conduct and Italian legislation