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Advisory on corporate tax residence and fictitious foreign residency risks

Service description:

Advisory on corporate tax residence and fictitious foreign residency risks

A&P provides specialized tax advisory services for Italian and foreign companies, with a focus on tax residency and the risk of fictitious foreign residency (esterovestizione). The analysis is conducted with reference to the criteria for determining tax residency, based on Italian legislation and international tax treaties.

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Consultants at Arletti & Partners are selected exclusively among associates and collaborators with proven academic qualifications, expertise, and professional experience. During the call, they provide answers strictly related to the selected topic and the jurisdiction specified in the service details, based on the questionnaire completed beforehand; questions outside these parameters are not considered a service failure. Appointments may be rescheduled only once within two business days before the call, and the consultation fee is non-refundable; the service is deemed delivered once the meeting ends within the reserved time. At the conclusion of the video conference, clients may complete a quality questionnaire to report feedback or issues, which the management will evaluate at its sole discretion. Invoices are issued within the month of payment. By booking the call, the client acknowledges and accepts these terms.

since 1998

Studio A&P offers professional consulting services to businesses and individuals.

Studio A&P supports companies and individuals with their activities in Italy and Worldwide, providing specialized assistance in global mobility of workers, Italian and international taxation.

years of
experience
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clients trusted
A&P in 2025
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Learn more about the topic with our guides

Highlighted info-sheet
Fictitious foreign company residency is an elusive phenomenon that consists in the dissociation between the formal and the effective residence of legal entities. It entails various consequences in the fiscal, administrative, and criminal spheres.
Highlighted info-sheet
The Tax residence's regime of legal entities in Italy has been amended by Legislative Decree No. 209/2023. The amendments concern the connecting factors, provided as alternatives, for the attribution of resident status.

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Tax Law

A&P Firm provides specialised advice on corporate tax residence in Italy. Our tax and corporate law professionals assist Italian and foreign companies in assessing tax residence and managing fictitious foreign residency risks, ensuring compliance with Italian and international tax regulations. The service aims to assess corporate tax residence and prevent presumptions of effective management in Italy, particularly during corporate planning or reorganisation phases. 

Latest news from the A&P Team

Permanent Establishment Art 5 OECD
Fictitious foreign company residency is an elusive phenomenon that consists in the dissociation between the formal and the effective residence of legal entities. It entails various consequences in the fiscal,...