Giuliana Polacco is highly proficient in all aspects of tax law. She regularly lectures on tax issues in various seminars and conferences, and has authored several articles and reports published in domestic and international tax publications.
Ms. Polacco advises multinationals — including software, pharmaceutical, medical and renewable energy companies — on the main areas of international taxation, with particular emphasis on transfer pricing, tax litigation, VAT, custom duties and cross-border reorganizations. She also assists clients in intercompany pricing, and represents them before the tax administration, especially in requests for tax rulings. Ms. Polacco also works on the resolution of tax controversies, including alternative dispute resolution techniques, litigation and assistance during tax audits. She has also counseled on matters regarding management fees, disallowance of tax credits and permanent establishment issues.
Representative Legal Matters
- Representing a US multinational consumer product company in litigation concerning the disallowment of management fees (value: EUR8 million).
- Representing a US multinational software group in litigation concerning the deduction of costs relating to cost-sharing (value EUR6 million).
- Representing a US multinational group involved in the silicon business sector in litigation concerning the value of royalties paid for the licensing of intangibles (value: EUR 16 million).
- Representing a French group involved in the food industry in a litigation concerning the disallowment of management fees (value: EUR2 million).
- Representing a US multinational in the medical devices industry in litigation, including the assessment of the PE of the foreign supplier (value: EUR500 million).
- Representing a US multinational in the medical devices industry in litigation for the disallowment of marketing expenses (value: EUR12 million).
Professional Associations and Memberships
- International Fiscal Association
- Milan Bar Association
- Italy (1994)
- University of Milan (J.D.) (1989)