Contact Gabriele

E: [email protected]
T: + 39 02 890 95 151

Gabriele Giardina
Partner


Office : RSM Studio Tributario e Societario - Milan
Services : Tax, Business Consulting
Sectors : Energy, Financial services, Manufacturing, Private Equity, Real Estate, Retail/Consumer Products
Biography

Dottore Commercialista (CPA) and Certified Auditor
President and member of the Board of Auditors of numerous companies in the industrial sector
Speaker at numerous courses and conferences

Career:

  • RSM Studio Tributario e Societario
  • Studio Gerla Associati
  • University of Leuven, Master of Laws (LL.M.) in European and International Taxation

Expertise:

  • Ordinary and extraordinary corporate tax consulting
  • Personal tax consulting
  • Tax litigation
  • Statutory auditing

Industries:

  • Industrial Equipment
  • Chemicals
  • Automotive

Membership in Service Line management groups within RSM Studio Tributario e Societario:

  • Consulting on direct taxation; International Tax
  • Transfer Pricing
  • Personal Income Tax Advisory & HNWI
  • Tax Litigation
  • Legal (Commercial & Civil Law)
Events

Extra-territorial taxation on Real Estate Entities' Capital Gains

Framework On 29 December 2022 the Italian Parliament issued Law No. 197 of December 2022 (hereinafter also “2023 Italian Budget Law”). The Italian Budget Law introduces a new territoriality rule – laid down by paragraph (1-bis) of Article 23 of the Italian Consolidated Act (“ITCA”) – according to which capital gain taxation is als...
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Italy enacts its own legislation regulating the tax treatment of Crypto-Assets

Within the framework of the Budget Law for 2023, in force as of 1 January 2023, specific provisions dealing with the tax profiles of Crypto-Assets have been introduced in the Italian legal system.[1] Until then, in the lack of specific rules set for by the law, it was possible to refer only to the clarifications of the Italian Revenue Agency p...
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Foreign trusts and the Italian lump sum tax regime: a favourable combination

Italy has not enacted an own specific legislation on the matter of trusts. However, on certain conditions, trusts are fully recognised in the Italian legal system as a result of the ratification of the the Hague Convention, come into force on 1 January 1992. From an income tax perspective, a specific regulation of trusts exists as of 2006. Indee...
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Good news for Italian resident individuals perceiving income from shareholdings in foreign companies

With judgement no. 25698 of 1 September 2022, the Italian Supreme Court made important clarifications concerning the income tax treatment of foreign dividends perceived by Italian resident individuals. As a matter of fact, the Italian Supreme Court has ruled the possibility for an Italian resident individual to benefit from the foreign tax credi...
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Smart Working and the risk of Permanent Establishment

The ongoing digitalization of the economy has undoubtedly allowed individuals to carry out work activities from their home without being physically present in an office, and in some cases to live in Countries where their employer has not a formal presence.  In this context, a relevant question arises on whether a “home office” in a Coun...
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A special tax regime to attract foreign pensioners to Southern Italy – Amendments to Article 24-ter Income Tax Act

“Inbound Pensioners” – General Overview In recent years, mostly inspired by the experience of other States, Italy has introduced several special tax regimes aimed at encouraging non-resident individuals to move (or to return to) and invest in the country.  The Italian Stability Law for 2019 (approved on 30 December 2018), added a n...
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The new R&D tax credit introduced by the 2015 Stability Law

In last couple of years, the Research & Development (R&D) Tax Incentive has caught significant importance in the international scenario, particularly in times of strong economic recession where innovation is seen as a key driver to encourage investments and produce economic growth. Italy is, among the EU countries, on...
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