INTERNATIONALIZATION AND TAX PLANNING

In a rising global market, where we see the crisis of the advanced and developed economies and a new trend to emerging countries, internationalization policies constitutes an important instrument against the European crisis – who did not arrange for time a plan of foreign investments turned out to be often in difficulty.

Enter in new markets, consolidate the ones already existent, project in other Countries investments such as productive plant, structures of assembly or distribution, of technical and maintenance assistance, commercials, real estate or financial, all suitable to allow that the vital process of internationalization at the base of global economy is a reward factor to the company’s success when it is well planned.

In this context, the Firm develops directly (regarding the aspects of operational planning and domestic tax planning) and in collaboration with a network of foreign professionals developed over the years, the services that allow the support of entrepreneurial initiatives cross borders, and in particular:

• assistance on choosing the adequate vehicle through which invest in the objective foreign country (subsidiary, branch, representative office, independent company, etc.);


• business plan activity, especially for the re-entry of the specific investments evaluation;


• domestic tax planning of the entrepreneurial initiative of internationalization, through the development and definition of the correlated issues, including:


• taxation of profits from foreign countries (conventions to avoid double taxation);


• problems involving relationships with tax heavens (black list);


• provisions on foreign subsidiaries and associated companies (CFC art. 167 and 168 of the T.u.i.r. – Italian Tax Consolidated Text);


• presumption of relocation abroad (art. 73 of the T.u.i.r.);


• tax credit for the incomes produced abroad (art. 165 of the T.u.i.r.);


• transfer of residence abroad (Art. 166 of the T.u.i.r. and the cd. – «exit tax»);


• monitoring rules for foreign assets (framework RW);


• financial assets held abroad (I.v.a.f.e. – tax on the value of foreign financial assets);


• real estate assets maintained abroad (I.v.i.e. – tax on the value of foreign real estate);


• problems involving cross border transfers of employees;


• study and preparation of models on transfer price policy for international groups with consultancy on the subject of contracts within the group;


• analysis of the civil, tax and labor Law of the objective foreign Country;


• assistance, directly or through professionals that are part of the local Italian Desk, for the execution of operational activities, related to the management of the entrepreneurial initiative (opening bank accounts, capital registration, translation and legalization, visa, temporary financial director, availability to represent the foreign shareholder, etc.);


• services of general accounting, balance sheet’s preparation, tax return, management and control of the paycheck;


• reporting activity to control the progress of the foreign business and in line with the accounting principles in use at the place of the company’s headquarters, also for the perspective of possible consolidation operations.