Tremonti Partners assists its clients in the planning and execution of a wide range of extraordinary transactions, from private equity, venture capital and leveraged buy-outs to the most complex reorganisations of national and international groups.

The Firm also has extensive experience in IPOs, tender offers, mergers, demergers and contributions, including cross-border transactions.

Our professionals are able to guide our clients through all phases of the aforementioned transactions, from due diligence, planning of investment structures (structuring) and incentive plans (carried interest), to negotiating and drafting contracts, drafting offering circulars, and implementing such structures up to the exit events.

In addition, the Firm can provide technical analysis, independent appraisals and fairness opinions in connection with acquisitions, sales and other extraordinary financial transactions (capital increase, demerger, transfer of business unit, etc.) as well as the valuation of specific assets (trademarks, etc.)

Tremonti Partners assists its clients in the management of tax issues that arise both in the course of the ordinary management of companies and in their enhancement and development phases. In particular, our professionals are skilled in dealing with the most complex accounting and tax issues, both for companies that adopt the domestic accounting standards and for those that adopt the IAS/IFRS.

Thanks to our in-depth expertise, our Firm is able to provide advice on the strategic planning of corporate groups.

In addition, the Firm provides specific assistance in relation to the use of various forms of tax relief, such as tax credits for research and development and technological and environmental innovation, as well as patent box “super-deductions”.

Over the years, the Firm has also acquired specific expertise in managing relations with the Italian Revenue Agency in the context of the cooperative compliance regime.

Our Firm advises banks, insurance companies, asset management companies, securities brokers, private debt funds and, more generally, the entire financial sector, in relation to Italian and international financial transactions.

Our activities in this area cover a wide range of advisory services, both in relation to the drafting and negotiation of multilateral financial agreements (including high-yield bonds), and also in relation to the preparation of opinions on legal and taxation issues, including those of considerable complexity relating to structured finance and capital markets transactions.

Finally, over the years, the Firm has assisted leading players active in the purchase, sale and management of non-performing loans and unlikely to pay.

Our Firm, which has been involved in cross-border transactions since its inception, advises its clients on the application of Italian rules with international scope, European regulations and double taxation treaties, taking into account the constant interpretative developments at both the EU and OECD level.

Thanks also to the support of privileged partnerships with leading tax firms located in the main European and non-European jurisdictions, the Firm accompanies its clients in their international activities, both inbound and outbound, providing ongoing assistance both in the global growth phases of companies and in the ordinary course of cross-border business management.

In particular, the Firm advises its clients on extraordinary cross-border reorganisations, such as relocations, mergers, demergers and contributions of business units.

Finally, the Firm assists its clients in analysing the implications of the most recent tax laws with a strong international connotation, such as hybrid mismatches and global minimum tax.

Tremonti Partners, through a dedicated team working alongside economists specialized in economic analysis and business valuation, is able to assist its clients in developing the qualitative, quantitative, and methodological analyses required by national and international transfer pricing regulations, as well as in preparing the relevant supporting documentation (Master File and Country File).

The Firm supports its clients during tax audits, pre-litigation procedures, and domestic litigation relating to transfer pricing matters.

In line with the most recent developments in international practice, Tremonti Partners has also gained extensive experience in mutual agreement procedures (MAP) and arbitration, as well as in unilateral (APA), bilateral (BAPA), and multilateral (MAPA) advance pricing agreements, having successfully activated several international rulings for clients operating in a wide range of industries.

In particular, with regard to this latter activity and specifically to bilateral procedures between Italy and the United States, Tremonti Partners also benefits from the support of its Washington, D.C. office.

Our Firm works with leading national and international real estate players in all areas of their activity (acquisition, leasing, financing, disposal, sale and lease-back).

Tremonti Partners also provides tax assistance in the area of investment structuring, which involves investment funds, SICAF and REITS, as well as the latest securitisation vehicles, depending on specific needs.

In addition to initial real estate transfers and assistance in resolving management and servicing issues, the Firm also assists real estate players and investors in resolving day-to-day operational issues.

Tremonti Partners has a long-standing tradition of managing relations with the Italian tax authorities and assisting in domestic and international tax disputes, with a particular focus on direct taxes, VAT, international taxation, transfer pricing, registration tax and local taxes.

We assist our clients in tax audits, dispute resolution procedures and all other extra-judicial proceedings, including tax settlements.

A specialised team of tax lawyers assists clients in litigation proceedings before the Tax Courts, the Supreme Court, the Constitutional Court and the European Courts. The Firm also assists clients in MAPs and arbitrations.

The Firm has gained considerable experience in tax refund procedures, both at administrative and judicial levels, with a particular emphasis on withholding taxes unduly suffered in Italy by multinational groups and foreign investment and pension funds.

Tremonti Partners assists clients in submitting all types of ruling requests to the Italian Revenue Agency, including rulings on new investments, APAs and cooperative compliance programs.

In the context of criminal proceedings for tax offences, the Firm advises and assists the criminal lawyers on the tax aspects of the case, including the preparation of expert opinions to be presented during the trial.

The Firm provides advice on family and estate planning, as well as asset protection (e.g. corporate structures, family agreements, trusts, foundations, etc.) while also advising clients on the use of instruments such as trust mandates and insurance policies.

Our professionals are also able to provide assistance in relation to tax regimes designed to encourage the transfer of residence to Italy (e.g. the so-called impatriate and flat tax regimes).

The Firm has also developed a specific focus on assisting with the governance and generational transfers of family businesses and the management of artistic assets and philanthropic and solidarity projects.

Thanks to its consolidated experience with various multinational groups, the Firm also advises companies and their executives on all aspects of the design and implementation of incentive plans, stock option plans, corporate welfare and any type of bonuses.

The Firm has gained extensive experience in VAT matters, and, with a dedicated team with in-depth knowledge of EU regulations, can assist both with regard to ordinary business operations and in the structuring of the most complex domestic and international transactions, including real estate and financial tax transactions, as well as in the context of group rationalisation processes (e.g. through the structuring of VAT groups).

Tremonti Partners has also gained extensive experience in registration tax and other indirect taxes (e.g., mortgage tax and stamp duty), as well as in the main local taxes (IMU, TASI, TOSAP and environmental taxes), advising on the main recurring and non-recurring issues.

For both VAT and other indirect taxes and local taxes, the Firm provides legal assistance in administrative audit and assessment procedures as well as in all phases of court litigation.