Federico Franconi

Federico’s practice focuses on assisting multinational groups in the field of corporate and international taxation, with respect to tax audits and disputes, as well as domestic and cross-border M&A transactions and corporate reorganizations.

Federico has extensive experience in managing complex tax audits, where he provides strategic advice and support in the negotiation. He has a proven track record in successfully negotiating with tax authorities to resolve disputes favourably and efficiently for his clients and successfully defend clients in courts. His expertise encompasses a range of tax-related issues, including tax claims arising from international tax planning schemes, permanent establishment, transfer pricing, withholding taxes and digital services tax.

Furthermore, Federico regularly handles domestic and cross-border M&A transactions and reorganizations, including tax structuring, SPA negotiations, due diligence, post-closing reorganizations and supply chain restructurings.

• Assisting a multinational group engaged in the pharmaceutical industry in the first Italian tax audit regarding hybrid mismatch rules deriving from business relationships with an Irish group company.
• Assisting several multinational groups in the tech industry in tax audits regarding the Italian digital services tax.
• Assisting a leading ITC multinational group with the tax aspects of several acquisitions of Italian companies.
• Assisting Sandaya (a leading French group in the glamping industry) in the acquisition of several campsites in Italy, as well as in post-closing financing transactions.
• Assisting a multinational conglomerate in a tax dispute regarding a tax abuse claim on an intra-group leveraged acquisition.
• Assisting several multinational groups in various industries in tax audits and disputes regarding beneficial ownership, permanent establishment and transfer pricing.