1.         Taxation of Companies 

Direct and Indirect Taxes

Studio Tributario Ummarino works closely with Italian corporations, subsidiaries and branches of foreign enterprises to professionally manage all tax issues pertaining to their ordinary business activities and capitalize on the tax economics associated with their organizational and strategic decisions.

The Firm provides on going assistance and tax opinions on all direct and indirect taxes, and on related corporate law and accounting issues. 

Tax Planning

The Firm’s goal is to develop innovative tax and legal solutions to enhance the client’s business purposes. 

With this goal in mind, the Firm also focuses on delivering advices on tax relief options in order to maximize the tax efficiency of the company and consolidated group.

The Firm also carries out internal tax audits concerning direct and indirect taxes, with a view to improving administrative actions and identifying any hidden tax risks.

Corporate Reorganizations and M&A

Studio Tributario Ummarino plans and implements the following transactions:  

• Transfer of shares.
• Transfer of going concerns, businesses and line of businesses.
• Mergers, de-mergers (spin-off), contribution of assets, liquidations and reorganizations. 

The Firm assists clients in the planning of their corporate and financial structures and group reorganizations.

Following the structuring of a transaction, the Firm provides assistance on all associated corporate and tax administrative matters.

The Firm also provides comprehensive tax due diligence.

2.         Taxation of Individuals 

Domestic and International Tax Planning

Studio Tributario Ummarino advises individuals on how to efficiently manage domestic and international tax issues associated with transfer of residency, transfer of shares, financial investments and in general with the disposition of private assets.

Structuring of Family Estates

The Firm’s practice covers all tax and corporate aspects relating to the management of family estates and the efficient transfer of family wealth. 

Studio Tributario Ummarino also offers technical tax studies and plans concerning inheritance instruments such as trusts and family foundations.

Tax Planning for Employers and Employees - Expatriates

Studio Tributario Ummarino works with domestic and multinational companies to design tax efficient compensation arrangements such as stock option plans, pension funds, and other fringe benefits. 

The Firm helps companies and expatriates to focus on tax, personal and business issues relating to cross-border secondments.  

3.         International and European Taxation 

International and European Taxation

Studio Tributario Ummarino assists its clients in every area of international and EU taxation for both direct taxation, Value Added Taxation (VAT) and other indirect taxation purposes.

The Firm closely follows the legislative documents and laws issued by the European Union in order to keep our clients up-to-date with any relevant tax and legal news affecting their businesses. The Firm also monitors the decisions of the European Commission and the case law of the European Court of Justice and of the Court of First Instance regarding fiscal State aid.

Transfer Pricing Issues

The Firm analyzes tax issues arising in connection with inter-company sales of goods or services, in the light of applicable transfer pricing rules. 

4.         Tax Litigation 

Representation of Clients before Tax Courts in all Litigation Stages

As regards disputes, Studio Tributario Ummarino represents its clients before tax courts at all litigation stages, including the Supreme Court. The Firm also represents its clients in civil proceedings concerning tax issues.

Letter Ruling Requests and Assistance with Tax Authorities

Studio Tributario Ummarino assists its clients in requesting letter rulings from Tax Authorities on a variety of issues including anti-avoidance provisions and the application of controlled foreign company legislation.

The Firm also provides assistance with Tax Audit procedures, and, in pre-litigation stages, represent our clients in negotiating with Tax Authorities with a view to settling the matter out of Court, and implementing all appropriate measures to obtain a non judicial settlement. 

5.         Administrative and Accounting Management  

Studio Tributario Ummarino works closely with Italian enterprises, subsidiaries and branches of foreign enterprises to professionally manage their administrative and accounting activities so as to provide a customized assistance to support their ordinary administrative and accounting needs and organizational decisions. 

In particular, the Firm carries out the following activities: 

• Implementation and administration of accounting systems.
• Administrative and accounting book-keeping.
• Balance sheet and consolidated balance sheet according to Italian, International (IAS/IFRS) and UK (UK Gaap) accounting principles.
• Execution of periodical financial reporting in accordance with Italian accounting principles or company’s principles.
• Balance sheet analysis, economical and financial planning.
• Readjustment and development of systems concerning the control of executive offices and business finance.
• Business plans to obtain State aids, tax relief and other facilities.
• Midyear audits of balance sheets and consolidated balance sheets.
• Periodical assessments of accounting book-keeping.
• Weighing and planning of accounting and audit procedures.
• Implementation of accounting book-keeping in public entities.
• Investigation audits to give management the right information for important decisions concerning mergers, acquisitions, joint ventures and business investments. 

Administrative and accounting management is offered either by the Firm independently at its offices or in cooperation with the client, via information links with its head offices or branches. 

This service may comprise an overall administrative management of all accounting, statutory or tax issues, or may be limited to specific areas. 

Book-keeping is carried out using sophisticated information systems, which also enable the processing of data and information useful in management operations. 

6.         Company Law

Studio Tributario Ummarino represents both domestic and foreign corporations for general corporate and commercial matters.

The Firm has a particularly active practice in mergers, acquisitions, joint ventures and shareholders' agreements.

Moreover, the Firm regularly counsels foreign entities in establishing a presence in Italy.

Mergers and Acquisitions

The Firm has considerable experience in the area of mergers, acquisitions, sales of companies and of holdings in companies, transfers of businesses or branches of business and corporate reorganizations.

Its activities in this field range from the preliminary activities to the conclusion of the transaction and include the negotiation of all the usual ancillary agreements to the principal agreement: loan agreements, guarantees, consultancy, supply and service agreements etc.

In addition to these activities, the Firm is able to provide clients with the tax assistance arising from the above-mentioned transactions.

Joint Ventures and Shareholders' Agreements

The Firm has developed considerable experience in negotiating shareholders' agreements and agreements between industrial partners and financing partners.

In this respect, the Firm also advises on the various forms of State aid available and on the proper company and tax structure for taking advantage of such forms of State aid.

7.         Litigation

The Firm's litigation department represents clients in complex legal proceedings.

The Firm's litigation department, which can count on the services of various experts in Italian civil law, represent clients both in civil/commercial litigation - both domestic and cross border - and in proceedings commenced before Administrative Courts.

8.         Real Estates

The Firm has considerable experience in the sector of the Italian Real Estate market.

The services provided include the drafting of sale agreements, leases, collateral for the same, the organization of due diligences in real estate matters and the management of agreements concerning real estate transactions within companies.

The Firm has acquired significant experience in administering blocks of owner-occupied flats.

9.         Contracts

The Firm deals on a daily basis with the negotiation and drafting on behalf of its clients of agreements for the sale and production of goods and services.

The services provided to its clients include representation in commercial and administrative litigation, which may arise in the performance of such contracts.

The Firm, furthermore, advises its clients on the impact of domestic and community anti-trust legislation on commercial contracts.

Simply by way of example, the Firm is more often asked to provide its services and assistance in the negotiation of agency, franchising, distribution contracts etc. and in the adaptation of standard form contracts - governed by laws other than Italian law – for the Italian legislation and practice.