Italy

Studio Tremonti Romagnoli Piccardi e Associati

Via Crocefisso, 12
20122 Milan
Italy

Tel: +39 02 58313707
Fax: +39 02 58313714
Email: caumont@virtax.it
Website: www.virtax.it

Cristiano Caumont Caimi has been a partner at Studio Tremonti Romagnoli Piccardi e Associati since 2009, and is based in the firm's Milan office. He is a practicing lawyer with 20 years of experience in the field of tax law. He specialises in tax litigation – starting from the tax audit phase up to the Supreme Court defence – pre-litigation settlements and advance ruling procedures, with a special focus on international taxation and transfer pricing issues. In addition, he has a high level of expertise in APAs and MAPs.

Cristiano joined Studio Tremonti Romagnoli Piccardi e Associati in 2002 and, since then, he has been engaged in professional practice with the firm's tax litigation team. He assists both domestic and international clients, including industrial groups, banks and insurance companies, telecommunications, energy and fashion groups, major real estate players and high-net worth individuals.

He was admitted to the bar in 2000 and to the Supreme Court in 2014.

From 2000 to 2002, he worked as a research associate at the International Bureau of Fiscal Documentation in Amsterdam as country specialist for Italy and Greece. From 1997 to 2002, he practiced law at Studio Uckmar in Genoa as an associate.

In 1997, he graduated with an honours degree in law from the University of Genoa and, in 2002, he received his LLM (with honours) in international taxation from the University of Leiden, Leiden (Holland).

He is the author of several articles published in the main Italian and international tax reviews and he regularly speaks at national and international tax conferences.

PwC

Via Monte Rosa, 91
20149 Milan
Italy

Tel: +39 02091605804; 348 2344239
Fax: +39 0291605499
Email: paolo.comuzzi@it.pwc.com
Website: pwc.com/taxcontroversy

Paolo Comuzzi has more than 16 years of professional experience practicing both with PwC and with other international tax firms in Italy.

Paolo holds both a degree in economics from Bocconi University in Milan and in law from State University and he is a qualified Italian certified public accountant and has been a registered tax expert within the Italian Ministry of Justice since 1991.

Paolo has gained a strong reputation on the market providing assistance in tax litigation and tax advice on relevant transactions. Additionally, Paolo is assisting on a continuative basis major domestic and international market players on tax compliance and fulfilment of tax requirements.

Paolo has significant expertise both in tax litigation (concerning international and domestic clients) and in mergers and acquisitions having participated in a number of important domestic and cross-border projects and tax litigations.

Paolo is on the board of auditors of many domestic and multinational companies and he was admitted as member of the Italian centre for criminal tax law.

He speaks both Italian (native) and English.

Cordeiro Guerra & Associati

Via De' Bardi 28
50125 Florence
ItalyTel: +39 055 2001611

Foro Buonaparte 12
20121 Milan
Italy
Tel: +39 02 76023340

Email: roberto@cordeiroguerra.it
Website: www.cordeiroguerra.it

Roberto Cordeiro Guerra is the founding partner of Cordeiro Guerra & Associati, established in 2003 with its main offices in Florence and Milan.

Roberto, who may rely on the support of 20 highly-skilled tax lawyers and chartered accountants, has 30 years of experience in assisting individuals, sports people and artists, companies and multinationals in tax litigations, tax audits and settlements with the Italian tax authorities in a wide range of issues, including transfer pricing, direct tax issues, VAT and other indirect tax issues.

Roberto advises Italian and foreign taxpayers on the tax aspects of corporate reorganisations, private equity, real property acquisitions, M&A, and financial transactions, among other things, providing a full expertise also in international and foreign tax issues.

He is a lawyer (avvocato) and full professor of international tax law at the University of Florence. Roberto teaches international, national and EU tax law in many post-graduate programmes. He is director of the post-graduate programme in criminal tax law at the University of Florence.

He is co-founder of Tax Law Quarterly (Rivista Trimestrale di Diritto Tributario) and permanent member of the Scientific Committee of Diritto e Pratica Tributaria Internazionale and of Rivista di Diritto Tributario Internazionale, the two most important international tax journals published in Italy. Roberto authored the book Diritto Tributario Internazionale. Istituzioni (International Tax Law. Institutions), whose second edition was published in 2016.

He graduated summa cum laude from the University of Florence in 1984 and from 1987 was admitted to practice in Italy and enrolled in the College of Advocates of Florence (Albo degli Avvocati di Firenze).

Roberto speaks Italian and English.

Deloitte Italy

Piazza della Vittoria 15/34
16121 Genoa
Galleria San Federico 54
10121 Turin
Italy

Tel: +39 010 5317811
Email: mcostigliolo@sts.deloitte.it
Website: www.deloitte.it

Matteo Costigliolo, Deloitte Italy, is a tax partner who previously worked with Arthur Andersen and a tax consultancy firm based in Milan and Genoa.

Matteo has more than 20 years of experience in national and international tax, group reorganisations, mergers and acquisitions, tax and corporate consultancy for multinational enterprises. He specialises in tax controversy and litigation, specifically assisting clients, usually large and medium-sized companies, in administrative proceedings in front of the tax authorities and matters heard by the tax courts. He also gives advice on all aspects related to tax audits, assessment and collection procedures and on administrative and criminal penalties, as well as other administrative procedures such as rulings or tax claims, for both Italian and foreign companies.

Matteo's clients are many of the largest Italian and international companies operating in a wide range of industries including shipping, logistics, automotive, steel, leisure and entertainment, oil and gas, banking and insurance, environmental services, construction, defence, aviation, pharmaceutical, chemical, information technologies, communications and telecommunication, professional sports, large retailers and food and beverage.

Matteo is member of the Statutory Auditors Board of Medium/Large Companies. He is a chartered accountant, statutory auditor and court consultant. He earned a degree in economics from Genoa University and served the Italian Navy as lieutenant.

Matteo regularly speaks about tax issues at domestic and international conferences and workshops in Italy, also on the request of the Revenue Agency and other public bodies. He regularly contributes articles concerning significant tax issues to specialised technical publications.

Deloitte Italy

Via XX Settembre 1
00187 Rome
Italy

Tel: +39 06 48990834
Email: edellavalle@sts.deloitte.it
Website: www.deloitte.it

Eugenio della Valle, Deloitte Italy, is a tax partner, a tax law professor at Sapienza University of Rome, and a tax lawyer (Avvocato tributarista). Prior to joining Deloitte, Eugenio worked with the Italian desk of one of the major international law firms.

Eugenio has over 25 years' experience in national and international tax, group reorganisations, mergers and acquisitions, tax and corporate consultancy for multinational enterprises. He specialises in tax controversy and litigation, specifically assisting clients, usually large and medium-sized companies, in administrative proceedings in front of the tax authorities and matters ruled by the tax courts. He also gives advice on all aspects related to tax audits, including assessment and collection procedures and on administrative and criminal penalties, as well as other administrative procedures such as rulings or tax claims, for both Italian and foreign companies.

Eugenio's clients are some of the largest Italian and international companies operating in a wide range of industries.

Eugenio is member of the Rome Bar, as well as member the Italian Tax Law Professors' Association. He earned a degree in law from Sapienza University of Rome and served the Italian Tax Police as a lieutenant.

Eugenio regularly either speaks at (or organises) domestic and international tax conferences and workshops in Italy, also on the request of the Revenue Agency, Tax Police and other public bodies. He is a member and sole director of the editorial boards and scientific committees of the most important Italian tax journals. He has written more than 100 publications, spanning from articles to books.

Eugenio speaks Italian and English.

Deloitte Italy

Via Tortona 25
20144 Milan
Italy

Tel: +39 (0)2 83324111
Email: sfedele@sts.deloitte.it
Website: www.deloitte.it

Stefano Fedele, Deloitte Italy, is a lawyer and tax partner with over 20 years' experience in domestic and international taxation. Stefano specialises in tax litigation and tax controversy, including representing clients in Italian tax, civil, criminal and administrative courts proceedings. He assists clients with restructuring and business planning operations and tax audits, and advises on administrative procedures of the Italian tax authorities, as well as all aspects of assessment procedures and administrative and criminal penalties.

Stefano assists clients with matters from audit to litigation, including every step of the administrative process. His litigation experience spans the full spectrum of issues, from VAT to corporate tax claims for both Italian and foreign companies. With respect to tax claims related to individuals, he advises clients relative to all aspects of matters that are before the Tax Court of I degree, the Tax Court of II degree and the Supreme Court.

Stefano serves many of the largest Italian and international companies, doing business across a wide range of industries including pharmaceutical, chemical, information, communication and telecommunications, logistics, automotive, hospitality, gas, banking and insurance, laundry and home care, large retailers and food.

Stefano has written articles for specialised Italian tax magazines and is engaged as a speaker at conferences.

He earned a Master of Tax Law degree from INFOR (Milan, 1995/1996) and was admitted to the Bar in 1998. Stefano is also qualified to represent clients in front of the Italian Supreme Court.

PwC

Via Monte Rosa, 91
20149 Milan
Italy

Tel: +39 02 91605807
Email: valentino.guarini@it.pwc.com
Website: pwc.com/taxcontroversy

Valentino Guarini is partner at PwC's tax controversy and dispute resolution network. He is based in the Milan office in Italy.

Valentino has achieved 22 years of experience inside the PwC network dealing with tax controversies. He also developed his experience through a wider range of activities in M&A, corporate restructurings, domestic and international tax advising.

Valentino and his team specialise in tax controversy and dispute resolution, handling assistance in the course of tax audits, as well as pre-litigation phases (settlements and rulings) and litigations before the tax courts.

He is an attorney-at-law before the tax courts and serves a wide range of clients (MNEs) in dealing with tax controversies, as well as providing tax advice on both domestic and international tax matters. He serves and advises clients in a variety of sectors with particular focus on consumer and industrial products, fashion and luxury, and pharmaceutical sectors.

Valentino is member of the International Taxation Commission of the Chartered Tax Consultants Council of Milan. He graduated both in economics and in law.

Ludovici Piccone & Partners

Via Sant'Andrea 19
20121 – Milan
Italy

Tel: +39 02 3032311
Fax: +39 02 30323190
Email: pietro.piccone@lptax.it
Website: www.ludoviciandpartners.com

Pietro Piccone Ferrarotti is a partner of the Italian tax law firm Ludovici Piccone & Partners. Pietro has more than 20 years of experience in the areas of tax controversy and litigation services. He gained significant experience in advising domestic and foreign clients in complex tax audits, pre-litigation and judicial settlements, and defence before tax courts and the Court of Cassation. His work ranges from legal services in relation to reviews, audits, disputes and litigation to strategic and legal advice on major transactions in Italy and abroad.

His areas of expertise include corporate and group taxation, M&A and business restructuring, real estate taxation, VAT, registration tax and other indirect taxes as well as excise duties and consumption taxes.

He is the author of publications on tax matters and he often speaks at tax conferences and lectures at post-graduate specialisation courses.

He graduated in law from LUISS – Guido Carli University in Rome. He attended a one-year full-time specialisation programme in tax law and tax accounting at management school at LUISS – Guido Carli University in Rome.

He is admitted to the Italian Bar Association in Rome. He is authorised to practice before the Court of Cassation and higher courts.

PwC Tax and Legal Services

Largo Angelo Fochetti 29
00154 Rome
Italy

Tel: +39 06 57127202
Mobile: +39 335 6075317
Email: carlo.romano@it.pwc.com
Website: pwc.com/taxcontroversy

Carlo Romano is a partner of PwC tax and legal services and he is the tax controversy and dispute resolution (TCDR) leader in Italy.

He is a tax lawyer with 22 years of experience, qualified to appear before the Supreme Court and has a PhD in international and comparative tax law (cum laude) from the University of Groningen, Netherlands. His areas of specialisation include domestic, European and international business taxation and transfer pricing.

Carlo has been involved in several leading national and international cases and has a broad experience in dealing with tax inspections, with pre-litigation settlements and with tax litigations also before the Italian Supreme Court and the European Court of Justice. He has gained a broad experience in advance pricing agreement negotiations, mutual agreement procedures and ruling practices.

He writes for various Italian and international tax journals and he is the author of various publications in international tax law. His book Advance Tax Rulings and Principles of Law (IBFD, 2002) is a milestone in the academic studies about rulings and APAs.

He has been a professor of tax law in various Italian universities, at the SSEF Scuola Superiore dell'Economia e delle Finanze (now SNA – Scuola Nazionale dell'Amministrazione) and visiting researcher at New York University. He regularly teaches in several courses for the officials of the Ministry of Finance and of the Revenue Agency as well as at LUISS and Bocconi Universities. He is scientific co-director of the criminal tax law course at the University of Rome "Roma Tre".

Carlo is member of the general council of the worldwide International Fiscal Association (IFA) and member of the executive committee of the Italian IFA branch.

Studio Tremonti Romagnoli Piccardi e Associati

Via Crocefisso, 12
20122 Milan
Italy

Tel: +39 02 58313707
Fax: +39 02 58313714
Email: zoppini@virtax.it
Website: www.virtax.it

Giancarlo Zoppini is a practicing lawyer and partner at Studio Tremonti Romagnoli Piccardi e Associati. Based in the Milan office of the firm, he specialises in tax litigation. His areas of expertise include settlements, advance ruling proceedings, legal defence in fiscal cases, providing assistance in tax audits, pre-litigation, litigation, and taxpayer representation in cases before the Italian Revenue Agency. He also acts as counsel in criminal tax cases.

Since joining Studio Tremonti Romagnoli Piccardi e Associati in 1993 (then called Studio Tremonti e Associati), Giancarlo has been engaged in professional practice with the firm and became a partner on January 1 2000.

Giancarlo received his degree in law (summa cum laude) from the University of Bologna in 1991. He passed the state exam at the first session (1993-1994) for the Court of Appeals in Milan and was admitted to the Milan Bar in 1995. A year later in 1996, he was admitted to the Accountant Auditors Association. Since 2007, he has regularly defended cases before the Supreme Court.

In 1988, Giancarlo graduated from a four-year degree course for officers in full permanent service at the Italian Tax Police Academy in Bergamo. From 1988 to 1991, he served as an officer in full permanent service with the Italian Tax Police engaged in tax and criminal matters. From 1991 to 1993, he was engaged in professional practice with another leading Italian firm, Falsitta e Associati.

From 1991 to date, he has published numerous articles and tax law essays in Italian scholarly reviews.