Michele Santocchini co-heads the tax practice of Baker McKenzie Italy. He joined Baker McKenzie's Rome office as counsel in 2013. A certified public accountant, he is knowledgeable in international tax planning, including supply chain restructuring, cross-border reorganization and acquisitions, financial restructuring and transfer pricing.
Mr. Santocchini also has vast experience in M&A matters, such as acquisition structuring, merger reorganizations and leveraged buyout. He has made several presentations on tax matters in events organized by the Rome CPA’s Association, and also lectures on advanced tax law at the University La Sapienza of Rome.
Representative Legal Matters
- Representing a US-based pharmaceutical group in a dispute valued at EUR72 million, relevant to the re-characterization of the Italian affiliate, operating as limited risk distributor of an Irish principal, as PE of this latter entity.
- Representing a US-based pharmaceutical group in a dispute valued at EUR40 million over three tax periods, relevant to the disallowance of management fees.
- Representing one of the largest brewers in South Africa in a dispute valued at EUR5 million, arising from a transfer pricing adjustment on a contract manufacturing agreement.
- Representing one of the largest entertainment US-based groups in a dispute valued at EUR2 million, arising from a transfer pricing adjustment on a copyright license agreement.
- Italy (2001)
- University La Sapienza of Rome (J.D.) (1995)
Author, “Il regime del riallineamento nella fusione inversa,” Bollettino Tributario, 2009
Author, “Il riallineamento delle partecipazioni,” Guida Normativa, 2010
Author, “La deducibilità dei versamenti a copertura del deficit patrimoniale,” nota a sentenza della Corte di Cassazione, Rassegna Tributaria, 2003
Author, “Il regime delle operazioni fra le società partecipanti alla fusione in caso di retrodatazione," La fiscalità delle operazioni straordinarie, Il Sole 24-Ore, 2002