Studio Corno Commercialisti e Aziendalisti. An approach oriented on pragmatism and extensive foresight to support individuals, families, companies and organisations in the daily and strategic management of their concerns, in Italy and abroad. In collaboration with the Firm’s lawyers.
Fiscal check-up
Studio Corno conducts a check-up on the client’s fiscal set-up, which involves a series of checks, also at the client’s premises, in the following areas:
• Timely keeping and retention of mandatory accounting books, suitability of the retained documentation • especially with regard to the transactions, at both and asset and/or liability level with other countries, – to meet all tax law requirements concerning the deduction of VAT, the deductibility of costs, the correct representation in the financial statements and the tax return forms;
• Main tax obligations, to ensure the respect of deadlines and suitability of the tax planning and budgeted amounts;
• Appropriate combination of the activities actually carried out and the relative Sector Study, analysis of the results, forecasting of possible effects, suggestions, opportunities, planning for subsequent years;
• Correct inventory accounting, where applicable or compulsory, with suitable presentation in the financial statements and tax return forms;
Tax litigation
• Direct assistance during tax audits, cross-checks, customs checks conducted by the Finance Police and/or Inland Revenue, drafting of pleas aimed at opposing the results of inspections, deductive reports on PAS, pursuant to the Statute of the Taxpayer, instances of investigations with prior adhesion to PAS or any assessment/rectification notices issued
• Assistance and representation in meetings at the Inland Revenue offices and related opposing reports as a result of questionnaires and/or invitations made to check the accuracy and adequacy of the figures reported, the consistency of the declared income with the income assessment system (Redditometro).
• Preparation of recourse/appeals against tax demands of the Inland Revenue (assessment/rectification notices, payment demands, collection activities of non-existent debt etc.) before the Provincial and Regional Tax Commissions, assistance and participation at court hearing through to the final sentence phase.
Transfer Pricing
The Firm supports customers in the preparation of documentation concerning the transfer pricing system and in reviewing the intercompany pricing policies.
Starting from the client business analysis, the experts:
• Identify the relevant transactions and the “value drivers”;
• Performs functional analysis on business activities and risks at a Group level;
• Analyse the transfer pricing policy currently in place;
• Check relative consistency also by comparing the “comparables” identified
• Prepare the “master file” and the “country files”, in line with OECD guidelines and regulations of the countries involved.
The work is performed by a multidisciplinary team that includes experienced tax experts, lawyers, business analysts, and financial analysts. The Firm also collaborates with its colleagues on the Russell Bedford International network, present in over 90 countries, as and when deemed necessary.
Other services include:
• Support in the drawing up of unilateral and multilateral agreements – Advance Pricing Agreements (International Ruling);
• Management of any disputes;
Patent Box
With the introduction of the “Patent Box” regime, Studio Corno assists business income recipients (from individual entrepreneurs to limited companies, including permanent organisations in Italy owned by non-residents) who have the right to economic exploitation of intangible assets, provided they carry out research and development aimed at the development, maintenance, and growth of the value of such intangible assets, providing a “key in hand” and modular service that supports the enterprise throughout all the stages and analyses required in order to obtain the benefit.
In this context the services include:
• Preliminary analysis and feasibility study for the evaluation of the overall tax benefit;
• Transfer pricing study, detailed calculations for the implementation of the Patent Box regime and calculation of the economic contribution of each individual IP;
• Reconciliation of eligible expenses;
• Analysis of possible business combinations and analysis of potential complementarity constraints;
• Complete assistance during the ruling procedure and further preliminary activities;
• Periodic monitoring of the implementation of the preferential taxation regime;
• Support related to the company’s need to comply with the tracking and tracing requirements (IT systems, processes, organisation).