Annarita De Carne

Associate

Italy

About me

                I am a tax advisor with more than 10 years of experience in advising domestic and multinational companies, on corporate income tax, withholding tax (WHT) and VAT purposes. I focus on tax disputes and tax risk management.
            

I have significant experience in advising domestic and foreign clients in tax audits, pre-litigation and judicial settlements, and defence before tax courts. My areas of expertise include corporate and group taxation, M&A and business restructuring, VAT, registration tax and application of double tax treaties.

More recently, I have also been focusing on tax risk management and have assisted several companies in defining and implementing tax control frameworks.

I am also a co-author of client alerts and articles on tax litigation, tax risk management and tax news.

My representative experience

Assistance in the course of tax audits and negotiations with the tax authorities for several companies in different sectors (software/hardware/fashion/banking/energy/consumer products) in the context of permanent establishment and transfer pricing cases (chemicals, agricultural, fashion, software).
Assistance in tax litigation regarding withholding tax assessments for major US companies (focused on the beneficial owner principles, qualification of income).
Assistance in the context of mergers and acquisitions in Italy and possible ruling procedure with the Italian Tax Authorities (e.g. tax attributes carrying forward, fiscal unit possible impairment).
Assistance to Italian multinational companies in defining and implementing tax control framework aimed at managing tax risks and/or adhering to the cooperative compliance programme.

My sectors & practice areas