A&M Tax Italy STP Srl (A&M Tax Italy) advises corporates, private capital funds and financial investors on the tax matters that shape strategic decision-making: acquisitions and disposals, group reorganisations, financing and restructuring, cross-border structuring, and the resolution of complex positions with the Italian tax authorities.
The team brings together professionals with proven experience in Italian and international taxation, providing specialist advice on tax due diligence, the structuring of corporate transactions, group reorganisations, tax integration in mergers and acquisitions, and other complex advisory matters.
Drawing on extensive experience in planning and executing complex M&A transactions and financial restructurings for domestic and multinational groups, A&M Tax Italy supports clients in navigating an Italian tax environment characterised by continuous legislative and regulatory change.
Why Choose A&M Tax Italy
Through a senior-led, hands-on approach, we build long-term, trusted relationships with our clients and support their tax needs through:
- High-quality, tailored advice: An approach grounded in a detailed understanding of each client’s operations, risks and opportunities, with bespoke solutions aligned to their commercial objectives.
- Integrated approach: Multidisciplinary collaboration with specialists from the wider A&M network, including Corporate Finance and Transaction Advisory.
- Independent advice: Advice delivered free from audit-related conflicts of interest.
- Specialist expertise: A team of tax professionals experienced in addressing complex matters across a broad range of sectors.
- Global tax solutions: Support from our international network in managing cross-border tax matters.
Our Advisory Services
Transaction Tax Advisory – M&A and Private Capital
- Tax structuring of acquisitions, disposals and joint ventures, including structure papers and step plans
- Buy-side and sell-side tax due diligence, focused on price-relevant findings, SPA protection and post-closing risk, including employment tax exposures
- Tax due diligence to identify material tax risks in connection with an IPO or share capital increase for listed companies, culminating in a Tax comfort letter
- Advice on acquisition financing structures, interest deductibility and debt push-down
- Economic analysis of financial flows and assessment of tax leakage across the holding structure
- Design and implementation of management incentive plans (carried interest, co-investment plans), for both the company and the participants
- Tax review of, and negotiation support on, transaction documentation (SPA, shareholders’ agreements, financing documents)
Restructuring and Financing Tax Advisory
- Advice on corporate reorganisations, mergers, demergers and contributions in kind, including advance clearance where appropriate
- Analysis and redesign of the value chain and of the group operating model
- Debt restructuring, debt waivers and conversions, and their tax treatment
- Definition of financing strategies and of the group capital structure
- Tax advice in distressed and turnaround situations, including negotiated settlement and insolvency procedures
International Tax and Transfer Pricing Advisory
- Planning and structuring of cross-border reorganisations and of inbound and outbound investment
- Permanent establishment analysis and management of permanent establishment risk
- Controlled Foreign Company (CFC) rules, including the optional substitute tax on the accounting profit of the foreign subsidiary, and analysis of hybrid instruments and mismatches under Italian and EU law
- Withholding tax, treaty and EU directive relief, and beneficial ownership analysis
- Pillar Two and global minimum tax: impact assessment, transitional and permanent safe harbour analysis, and group readiness, and preparation of the GloBE Information Return and the related domestic filings
- Public country-by-country reporting: scope assessment, preparation and publication of the report, and consistency of the narrative with the group’s transfer pricing position across the jurisdictions concerned
- Transfer pricing policy design, benchmarking analysis and alignment with the value chain, with the supporting documentation prepared as an extension of the advice
- Advice on international employee mobility and on cross-border employment structure
Ongoing Tax Advice and Assistance
- Management of the ongoing tax compliance and advisory for direct taxes (IRES and IRAP), VAT and withholding taxes
- Day-by-day assistance
- Advice on the corporate tax treatment of complex transactions, with the related reporting managed end-to-end
- VAT and indirect tax advice on supply chains, cross-border flows and contractual arrangements
- Advice to foreign investors on establishing and maintaining an Italian tax footprint, including the related obligations
- Employment income tax advice and the related filings
- Preparation of the statutory documentation supporting the positions taken
Tax Controversy and Dispute Resolution
- Pre-audit readiness reviews and strategic management of the pre-litigation phase
- Assistance during tax audits and in settlement procedures, including the mandatory pre-assessment adversarial proceedings (contraddittorio preventivo)
- Assistance and technical representation in tax litigation before the tax courts of first- and second- instance tax courts
Reward, Mobility and Employment Tax Advisory
- Design of reward and incentive structures, including equity-based and cash-based plans
- Tax and social security advice on international mobility, secondments, business trips, business travellers and remote working
- Advice on the most suitable structure for cross-border assignments, and support with its implementation
- Advice on employment income (domestic taxation, payroll, labour and social security) and on labour cost optimisation
- Advice on people strategy: staff incentive strategies and internal policies
- Advice on the implementation and optimisation of corporate welfare plans and on compensation & benefits
- Advice on the tax and social security governance of the HR function
Private Client and Family Office Advisory
- Advice and planning for High Net Worth Individuals (HNWI) and entrepreneurial families
- Analysis of the Italian tax regimes designed to attract individuals to Italy, including the substitute tax regime for new residents, at its current entry threshold amount and with the extension to family members, and the inbound workers regime, together with the restrictions on combining the two
- Succession and generational transition planning, including family agreements
- Trusts, holding structures and family governance
- Tax advice on private investments, carried interest and co-investment participations
