Tax regulations are periodically subject to specific changes, which – especially in times of crisis – prompt the lawmakers to envisage new grounds for criminal prosecution, or to toughen penalties, or to affect the procedural aspects related to tax crimes.
Over thirty years of intense judicial activity aimed at countering tax evasion have passed, from Law no. 516/1982 to Legislative Decree no. 74/2000, up to the latest changes introduced by Law no. 148/2011 and, more recently, by Legislative Decree no. 158/2015 (entered into effect since 22 October 2015), which has revised the disciplinary systems of tax crimes.
A number of complex issues may fall under the umbrella of tax law. These include transfer pricing criminal liability, the use of an offshore company/offshoring, the correct treatment of royalties, the exact identification of the concept of fictitious expenses as well as voluntary disclosure.
Over the years, the difficulty in interpreting some tax regulations has sparked off numerous doctrinal debates, thus providing some food for thought for the defence counsel.
Topical issues also include a detailed study of assets confiscation, money laundering and self-laundering. The firm also relies on several accredited tax law experts.
The firm offers in-depth analyses of tax-related offences through conferences, study groups and publications. Please see the relevant section of this website for further details.