Annarita De Carne

I have almost 20 years of experience in advising domestic and multinational companies on corporate income taxes, withholding tax (WHT) and VAT purposes.

I was admitted to the Association of Chartered Accountants in 2006 and joined Bird & Bird in 2019 after having worked with other international law firms. I am currently Counsel in the Tax Department at the Milan Office of Bird & Bird.

I gained extensive experience in assisting domestic and foreign clients in complex tax audits focused on PE claim, Transfer pricing, Withholding tax and VAT; as well as pre-litigation and judicial settlements, and defense before tax courts.

I have also been focusing on tax risk management and assisted several companies in defining and implementing tax control frameworks. I am co-author of client alerts and articles on tax litigation, tax risk management and tax news.

• 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.