Cioni & Partners

Our advice and professional assistance in tax covers both direct and indirect taxes. In particular, the studio is specialized in providing:

• advice on the application and interpretation of tax laws;
• assistance in the field of international taxation;
• tax planning;
• assisting customers in start-up, management of current taxes and extraordinary opportunity;
• advice and assistance in the determination of income taxes in the financial statements;
• assistance and advice in the evaluation of the conditions of accession and operational management of the consolidated fiscal institutions (national and global) and fiscal transparency;
• assistance and advice to customers at the offices of the tax (Internal Revenue Service, Agency of the territory, Customs Agency, the Regional Directorate of Revenue and the Ministry of Economy and Finance);
• assistance and advice to local authorities.

Ever since the publication of the first draft regulations, and gradually more thoroughly, until the definitive entry into force, the Study has dedicated a significant part of its resources to the study and application of the Tax Reform introduced in early 2004. Through this activity the members of the Study have gained extensive knowledge and experience, theory and application of new rules and their application in terms of tax planning. In particular, our experts, as well as the practical application of new institutions in respect of customers affected, have played in the past and continue to engage in teaching courses and conferences designed to make known to the insiders of the technicalities, the advantages and disadvantages of the rules characterizing the reform, such as Consolidated fiscal Transparency, participation exemption, the tax treatment of dividends and new rules on the deductibility of interest expense (Thin Capitalization and Asset Pro-rata).

The international tax planning is carried out by experienced specialists using the help of established international collaborations. We are organized to assist each business type, from family businesses to those of medium and even large corporations with innovative solutions built to specific customer requirements. In particular, we specialize in structuring and monitoring the adequacy of transfer pricing policies among corporate groups in harmony with the new laws on the subject of International Ruling, in the drafting of requests addressed to the Tax Authority to agree appropriate procedures Transfer pricing governing commercial transactions and transnational flows of dividends, royalties, interest and imputation of income from permanent establishments and their Head Offices.

We are specialized in carrying out checks on the tax position of companies and groups of companies, in particular in connection with acquisitions, investments, etc..
In particular, we verify the correct application of tax rules, the situation of litigation, existing or potential, estimating the potential risks, evaluate the correctness of the procedures of transfer pricing and their acceptability by the tax authorities.

We assist our customers in checks carried out by the competent bodies to access, control, inspections and audits (Financial Police, Inland Revenue, Customs Agency, Department, etc.) according to the rights guaranteed by Article 12 of Law 27/07 each taxpayer / 2000, no 212 (Taxpayer Rights and Guarantees subject to tax audits - cd. Statute of the Taxpayer). The activity is also projected its consequential even after the closure of the audit, for the cd. deflationary phase of the litigation (more memory, self-protection, etc..).

We are specialized in assisting and advising in tax disputes, defending taxpayers continue providing tax appeals courts, using the memories and permanent contact with the Inland Revenue, considering where he fulfilled the conditions, the opportunity to appeal deflationary institutions in the litigation (with membership determination, conciliation court, etc..).

The Study provides assistance and advice to businesses since its establishment, dealing with all the ordinary and extraordinary. As an example, among the activities in which we specialize:

• preliminary analysis on the choice of most suitable companies to realize the expectations and needs of the customer, provision of the bylaws, analysis and advice on opportunities in the drafting of shareholder agreements and fulfillment of all obligations relating to:
• advice on the turnaround (rehabilitation and revival of companies);
• advice and assistance in the establishment of trusts;
• assistance and advice in the sale contract / acquisition of companies and equity packages;
• mergers, acquisitions, transfers, rental business, and corporate reorganizations;
• due diligence in corporate and legal;
• procedures for voluntary winding up of companies and organizations;
• expertise in civil, criminal and tax law.

Our Study has had occasion to deal with numerous cases of generational transitions, developing specific expertise in the field, having some of our members a special expertise and sensitivity in advising family businesses.
We also provide assistance in extraordinary transactions, in the process of M & A and LBOs, MBOs, MBIs, both in pre-contractual negotiations, both during the initial planning of the operation, providing assistance in the design and preparation of the project, both in 'implementation of the transaction by following step by step until the final completion of the development.
For several months the Study is devoting a major part of its resources and deepening the application of corporate law reform came into force in early 2004, also as regards the adaptation of the novel regulatory statutes. Through this activity the members of the Study have gained extensive knowledge and experience in applying the new rules and their effects on the activity of the companies and their shareholders.

Our Study provides assistance and advice to companies regarding preparation of financial statements and consolidated financial statements, made in compliance with applicable national and international accounting standards (IAS, IFRS, U.S. GAAP), among other things, considering the additional requirements documents introduced by the recent UCI. Our Study is also specialized in helping and formalization of corporate resolutions, and all related and all matters relating to the ordinary and extraordinary management of the Company.

Routinely we carry out functions of auditors and auditors as required by the new regulations of the Civil Code novel by D. Decree Law 6 / 2003). Beyond their functions and tasks of these offices, we are used to interpret our statutory functions / auditors as an important opportunity to meet professional, designed to provide a more comprehensive and shared comprehension of the phenomena and events to corporate stakeholders.

Some members of the Study are experienced in carrying out corporate assessments and the preparation of subsequent appraisals (to be used even in the sale of company, in determining the appropriateness of the values??, the exchange ratio in extraordinary operations, for capital gains, etc..).
The members are also experienced in performing financial analysis of the budget, to investigations of credit with banks and financial institutions.
The Study specializes in monitoring the adequacy of the position of business customers under the parameters of the CD. legislation "Basel 2" in order to assist companies in achieving adequate parameters and explore the best possible access to credit. The Study assists companies Customers also with regard to the evaluation and selection of financing alternatives are better suited to business needs, evaluating the best structure of the debt with regard to the prerogatives and the specificities of each company.

We arranged a service to customers in the economic, business and finance to provide to those who need it useful elements for a more rational economic management / asset complementing the financial. This business has developed significantly as a result of the economic difficulties faced by business, increased competition and the relocation of the stimuli.

In increasingly difficult economic times, with increasingly competitive and unstable markets, the companies requires a planning and control of economic and financial events very carefully. To go from a "visual navigation" to a company with a reliable and timely management control, the Cioni & Partners has developed a set of methodologies aimed at the advanced management planning process (Budget and pricing) and control (Reclassification of Budget, Accounting and Business Analytics, etc..).

The organization is the "engine" that drives the primary company towards achieving its strategic objectives. To optimize and maximize the operation of this engine is essential that all components are properly designed, sized and move in a synchronized, effective and efficient.
In this area the Study Cioni & Partners operates through a global approach is both analytical construction / revision of organizational structures, using the following services:
- Organizational Check-up
- Drafting / Revision of Organization
- Formalization of job descriptions and responsibilities
- Formalisation / Optimization Organizational Procedures
- Revision of the Organizing Corporate Functions
- Analysis of the Business Climate

The study Cioni & partners has proposed for years with great success training very interesting and large influx of participants.
The courses are characterized by extremely practical cutting, which allows participants to immediately apply the concepts explained in the reality of their company.
The various training initiatives are realized by us both independently and in collaboration with the leading industrial associations and include the following areas:
Organization area:

• The definition and formalization of the organization, duties and responsibilities
• MBO: how to set up the company management by objectives

Administration Finance and Control Area

• The reclassification of the general ledger and asset for economic control
• The accounting system for monitoring the efficiency of the industrial structure and to calculate the profitability of products
• The management accounting: issues and tools to guide the company strategically
• The pricing structure for successfully selling prices
• The Activity Based Costing
• The construction budget for the planning of activities
• Evaluate investments: how to calculate the cost, the return and the financial commitment
• Balanced scorecard: measure performance, communicate the strategy

We assist our customers in the financial decisions in complex situations. In detail, the activities of assistance consists in defining the strategic objectives of companies and identification of extraordinary transactions that meet these objectives, the corporate finance transactions, including mergers and acquisitions, joint ventures and partnerships, divestiture and spin-offs, restructurings liabilities through the economic and financial analysis of the company / group, scenario of financial balance, negotiating with its major creditors, structuring of medium / long term care and the issuance of debt securities and other operations attached.
Particular attention is also in the search for financial partners and / or industry to support the growth in size of the company.
We also specialize in corporate restructuring (LBOs, MBOs, divisions, operations of an inheritance-tax), as well as assessments of stand-alone company in the determination of exchange rates.
Finally, we assist our Customers in the relations with institutional bodies (Consob and the Italian Stock Exchange).