HEADQUARTERS
Milan
studiomi@uckmar.com
ACTIVITY AREAS.
– Tax advice to companies traded in regulated Italian and foreign markets.
– Tax assistance in complex corporate reorganization transactions.
– Financial and international taxation consulting for leading Italian and foreign banks and insurance companies.
– Legal aid before the Tax Commissions, Court of Cassation, and Constitutional Court.
PROFESSIONAL TITLES AND SCIENTIFIC QUALIFICATIONS
Partner of the Uckmar Firm Professional Association since October 2008.
– Full Professor of Tax Law in the University of Brescia, Department of Law, from January 2019.
– Lawyer registered as a member of the Milan Bar since 2001 and Patrocinante in Cassazione since 2011.
– Certified Public Accountant registered as a chartered accountant in Milan since 1994.
– Qualified Full Professor of Tax Law since May 2015.
– Associate Professor of Tax Law in the University of Brescia, Department of Law, since December 2010.
– PhD in international and comparative tax law in the University of Genoa (February 29, 2000). Doctoral thesis: “International and comparative aspects of the regional business tax.”
– Bachelor’s degree in Law, awarded on March 18, 1996, from the State University of Milan, with a grade of 110/110 cum laude.
– Thesis discussed: “International and EU tax law relations between Italy and Germany,” supervisor Prof. Alberto Santa Maria.
– Postgraduate course in corporate tax law from a.y. 1992/93 at “L. Bocconi” Commercial University of Milan.
– Bachelor’s degree in Business Administration, majoring in liberal professions, awarded on July 9, 1992, at the “L. Bocconi” Commercial University of Milan with a grade of 110/110 cum laude. Thesis discussed: “Tax aspects of German reunification,” thesis advisor Prof. Victor Uckmar.
JOURNAL EDITORSHIP AND EDITORIAL BOARDS
– Among the Coordinators of the Editorial Board of “Tax Law and Practice,” Member of the Editorial Board of “International Tax Law and Practice.”
– Editor-in-chief of the journal Financial Instruments and Taxation.
COORDINATION OF UNIVERSITY MASTER’S DEGREES
– Coordinator of the second edition of the Master’s Degree Program in “Heritage Governance and Generational Transition,” in the University of Brescia, academic year 2017/2018.
– Among the Coordinators of the Master of Tax Law in the Catholic University of Milan, academic year 2017/2018.
LANGUAGES
Excellent knowledge of German and English.
Publications
PUBLICATIONS, REPORTS AND ARTICLES
– Tax law of financial activities, Egea, Milan, 2012, 943.
– Profili Tributari dei conferimenti in natura e degli apporti in società , Cedam, Padua, 2008, 599. [Series the International Tax Law, in collaboration with Victor Uckmar and Paolo de’ Capitani, Cedam edition, 2009.
– Manual de Derecho Tributario Internacional, in collaboration with Victor Uckmar, Paolo de’ Capitani and Mauricio Plazas Vega, Temis edition, Bogota, 2010.
– Short Commentary on Tax Laws, Volume II, Assessment and Penalties, Articles 23-30 and 72-74, Cedam, 2011.
– Elements outside the deed irrelevant to the redetermination of the registration tax, in G.T., 2011, 790-797.
– The Coordination between tax rules and international accounting standards for financial instruments in Corriere Tributario, Milan, no. 27/2011, p. 2198-2204.
– Equity Exchanges and International Accounting Standards, in La Fiscalità delle società IAS/IFRS, Handbook (edited by G. Zizzo), Milan 2011, 765-790.
– The family covenant, in Notarial Acts. Community and international law, Turin, 2011, 1765-1832.
– Intended Assets , in Notarial Deeds. Community and international law, Turin, 2011, 1833-1846.
– The applicability of the participation exemption to transfers of warrants, in Financial Instruments and Taxation, 2011, no. 4, 77-84.
– Conditions for the recognition of tax credit for foreign “artistic” income, in Taxation and International Trade, 4/2011.
– Brief notes on tax autonomy in the German tax system, in Fiscal Federalism and Autonomy of Territorial Authorities, edited by A.E. La Scala, 2010, 259-266.
– The controversial (il)legitimacy of the adjustment of the capital gain from the sale of a company based on the value of goodwill defined for registry purposes, in G.T., 2010, 711-717.
– Corporate reorganization with spoliation of Italian assets does not constitute business transfer, Comm. Trib. Prov. of Milan, Sec. I, sent. September 29, 2010, no. 396, in Giur. Trib., 3/2011.
– Article 20 of the T.U. of the registration tax and the tools for combating avoidance: brief reconstructive insights in the margin of two contrasting pronouncements of the case law, in Dir. prat. trib., 2010, 565-585.
– Equity exchanges and international accounting standards, in Dir. prat. trib., 2010, 289-314.
– Brief notes on the adjustment of capital gain on sale of business on the basis of the value finally assessed for registration tax purposes, in Dir. Prat. Trib., 2010, 67-80.
– Taxation Profiles of Fiduciary Intestacy, in Obligation and Contracts, 6/2009, 548-558.
– Brief notes on the recent changes introduced in the taxation of business transfers, in Dir. prat. trib., 2009, 531-543.
– Taxation of business transfer and transfer of real estate leases, in Corr. Trib., 2009, 2197-2203.
– Tax autonomy in the German tax system, in Dir. prat. trib., 2009, 213-249.
– On the general prohibition of abuse of rights in the tax system, note to Cass., United Sections, Dec. 23, 2008, No. 30055, No. 30056, No. 30057, in Dir. prat. trib., 2009, 303-313.
– The substitute tax in extraordinary transactions, in Tax Review, 2008, 662-679.
– Brief notes on the obligations of trust companies following the (re)established inheritance and gift tax, in Trusts and Trust Activities, 2008, 262-270.
– The nullity of contracts as a tool to counter dividend washing operations in recent Supreme Court jurisprudence, in Bonds and Contracts, no. 4/2006, 302-331.
– Dedicated assets, dedicated financing, financing for a specific business and project financing: corporate and tax profiles, in Dir. Prat. Trib., 2005, 309 ff.
– The tax regime of financial instruments, in The new corporate income tax , in Riv. Dr. Comm., special annex to no. 3/2004.
– The investigative powers of the tax authorities against trust companies, in Dir. Prat. Trib., 2004, 313 ff.
– Shares, participatory financial instruments and bonds: from company law reform to corporate income tax reform, in Dir. Prat. Trib., 2003, 875 ff.
– IRAP and employee employment: the structure of the tax, constitutional justification and phasing out, in Employee Employment in Tax Law, edited by Nicola D’Amati, CEDAM, 2003, 636 ff.
– Tax Profiles of Electronic Commerce, in Electronic Commerce, Computer Document, and Digital Signature. The new discipline, edited by Giusella Finocchiaro – Carlo Rossello – Emilio Tosi, Giappichelli editore, 2003.
– Tax aspects of commodity derivative contracts, in Dir. prat. trib., 2002, 851 ff.
– Dividends, Interest, Royalties and Capital Gains in the OECD Model,” in AA.VV., Course in International Tax Law, coordinated by Victor Uckmar, 2nd edition, Padua, Italy, 2002.
– The OECD Model Bilateral Double Taxation Convention and Trusts, in AA.VV., Corso di Diritto Tributario Internazionale, coordinated by Victor Uckmar, 2nd edition Padua, 2002.
– The convention between Italy and Germany against double taxation, in Le convenzioni dell’Italia in materia di imposte sul reddito e sul patrimonio, commentario edited by Carlo Garbarino, Egea, 2002, 219 ff.
-IRAP: the elements of the taxable case, constitutional justification and gradual repeal, in Dir. prat. trib., 2001, 971 ff.
– Notes on nonresident trusts and resident beneficiaries, in Trusts and Trust Activities, 2001, 376 ff.
– The lineaments of the new tax regulation of private pension and insurance contracts, in Dir. prat. trib., 2000, 255.
– Brief notes on the tax profiles of the securities trust, in Trusts and Trust Activities, 2000, 290 ff.
– The international and comparative profiles of the regional tax on production activities, in Dir. prat. trib., 1999, 427 ff.
-Dividends, interest, royalties and capital gains in the OECD Model, in AA.VV., Corso di Diritto Tributario Internazionale, coordinated by Victor Uckmar, Padua, Italy, 1999.
– The OECD Model Bilateral Double Taxation Convention and Trusts, in AA.VV., Corso di Diritto Tributario Internazionale, coordinated by Victor Uckmar, Padua, 1999.
– The tax regime of income from participation in collective investment schemes, in Dir. prat. trib., 1999, I, 751 ff.
– The Discipline of International Avoidance in the German Federal Order,” in Studies in Honor of Victor Uckmar, Padua, 1997.
– The elimination of double taxation in the Italian and German federal legal systems, in Dir. prat. trib., 1997, 433.
– The new Italy-Germany tax treaty, in Tax Planning International Law Review, 1993, 2 .
