Annarita De Carne

I am a tax advisor with almost 20 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.

• 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.