<\/p>\n\n\n\n
Genoa \/<\/strong> Milan<\/strong><\/strong><\/p>\n\n\n\n studioge@uckmar.com studioge@uckmar.com<\/a> – Corporate and tax law, international taxation, financial taxation, extraordinary transactions, tax planning for corporations and individuals, tax and corporate litigation, consultant to Istat in the project. “Measurement of new variables on the structure and activities of multinational companies”; participates in the research project on the tax aspects ofEmission Trading<\/em> conducted by Studiare Sviluppo S.r.l. Partner in the Uckmar Firm Professional Association since December 2006<\/p>\n\n\n\n – Barrister – Harvard Law School: International Tax Program. English, German and Spanish (very good level), French<\/p>\n\n\n\n <\/p>\n\n\n\n – Will multinational web companies also have to pay VAT?\n– The IRS and the Law – The Discussion <\/a><\/p>\n\n\n\n – Taxes on extraprofits?\nHandle with care…- The IRS and the Law – The Discussion <\/a><\/p>\n\n\n\n – War in Ukraine weighs on international trade – The IRS and the Law – The Discussion<\/a><\/p>\n\n\n\n – Soccer betting and league rights – The IRS and the Law – The Discussion<\/a> <\/p>\n\n\n\n – A feudal tax system hits young people – The IRS and the Law – The Discussion<\/a><\/p>\n\n\n\n – Harvard grappling with alleged “quotas and discrimination” – The IRS and the Law – The Discussion<\/a><\/p>\n\n\n\n – Energy.\nSupertax on producers?\nCaution – The IRS and the Law – The Discussion <\/a><\/p>\n\n\n\n – Tax reform from dream to reality – The IRS and the Law – The Discussion<\/a><\/p>\n\n\n\n – Tax reform.\nWhat impact on citizens?\n– The IRS and the Law – The Discussion <\/a><\/p>\n\n\n\n – A tax for growth, simple and fair?\nIt can be… but – The IRS and the Law – The Discussion <\/a><\/p>\n\n\n\n – Taxes, amnesties and inequities – The IRS and the Law – The Discussion<\/a><\/p>\n\n\n\n <\/p>\n\n\n\n <\/p>\n\n\n\n – The<\/em> French branch profit tax and its compatibility with the free movement of capital guaranteed by EU law. Points of comparison with the Italian taxation of outbound dividends under Article 27, Presidential Decree No. 600 of 1973, in Dir. Prat. Trib. Int.<\/em>, 3\/2024, p. 900<\/em>. <\/p>\n\n\n\n ASLA DAC6 Tax Planning.pdf (aslaitalia.co.uk)<\/a><\/p>\n\n\n\n The extraordinary levies on energy enterprises. Taxation of extraprofits or revenue avocation? – ICC Italy Italian National Committee of the International Chamber of Commerce<\/a><\/p>\n\n\n\n International trade in wartime – A voice from Ukraine – ICC Italy Italian National Committee of the International Chamber of Commerce<\/a><\/p>\n\n\n\n
<\/strong>studiomi@uckmar.com<\/a> <\/p>\n\n\n\nACTIVITY AREAS.<\/h5>\n\n\n\n
– Chairman of the ICC Italy Tax Commission.
– Chairman of the Board of Statutory Auditors and Supervisory Board of Volkswagen Financial Services S.p.A.
– Chairman of the Board of Statutory Auditors of Volkswagen Mobility Services S.p.A.
– Member of the Board of Directors of Elah Dufour S.p.A.<\/p>\n\n\n\nPROFESSIONAL QUALIFICATIONS<\/h5>\n\n\n\n
– New York Bar
– Case Lawyer since 4\/22\/2016 following qualification by examination under Article 22 Law 247\/2012<\/p>\n\n\n\nTRAINING<\/h5>\n\n\n\n
– University of Pisa: PhD in Private Law.
– University of Genoa: Law degree 110\/110 with honors and dignity of press.
– University of Mainz: Johannes Gutenberg Erasmus Program.<\/p>\n\n\n\nLANGUAGES<\/h5>\n\n\n\n
\n\n\n\nRubrics<\/h2>\n\n\n\n
\n\n\n\nPublications<\/strong><\/h2>\n\n\n\n
PUBLICATIONS, REPORTS AND ARTICLES<\/h5>\n\n\n\n
– The extinction of entities between succession and liability: from civil law premises to tax solutions<\/em>, CEDAM, Padua, 2023.
– The<\/em> 2022 and 2023 Italian windfall profit (?) tax(es) on the energy sector: lessons to be learned, in International Tax Law and Practice, 2023\/2, pp. 367-402<\/em>.
– DAC 6 and the reporting requirements of aggressive international tax planning transactions: the American inspiration and the new role of professionals, in International Tax Law and Practice, 2021, 4, 1522<\/em>.
– The Italian web tax<\/em>, between European aspirations and international reality, in Journal of the Guardia di Finanza, 2021, p. 655<\/em>.
– The car tax stamp and “young historians,” in Dir. Prat. Trib. 1\/2020<\/em>.
– The Financing of the Regions, AA.VV., edited by L. Del Federico and C. Verrigni, in La finanza pubblica nei vari livelli di Governo, Giappichelli, 2019<\/em>.
– Fiscalit\u00e9 Internationale, 2019, nos. 1, 2, 3, 4.
– The Taxation of Business Income from the League of Nations to the Digital Economy, in AA.VV., edited by Glendi-Corasaniti-Oliva-de’ Capitani di Vimercate<\/em> , Per un nuovo ordinamento tributario, CEDAM, 2018<\/em>.
– On the <\/em>nature of the anti-avoidance assessment notice under Article 10-bis and its relation to the principle of unitary assessment, in Dir. Prat. Trib., 2016\/5, p. 1870.<\/em>
–<\/em><\/em> The star companies, in Dir. Prat. Trib. Int., 2015\/4.
– <\/em>Voluntary Disclosure for Trusts and Foundations, in. Dir. Prat. Trib. Int., 2014\/4.
–<\/em> On the constitutional illegitimacy of facilitative provisions on transfers of companies and corporate holdings free of charge and by inheritance, in Dir. Prat. Trib. Int., 2014\/4.
– <\/em>Le bandiere ombra , in Proceedings of the conference Il Mare e il Fisco, Nola October 24-25, 2014 (CEDAM ebook).
– About to be Published The Taxation of Business Income from the Society of Nations to the Digital Economy, in the volume of CEDAM conference proceedings.
– <\/em>Le azioni e i titoli similari, G. Corasaniti (ed.), in Financial Instruments in Business Taxation, Egea, 2013 (co-authored with O.D. Piccoli).
–<\/em> Nullity of contracts as a penalty for violation of tax provisions, in Treatise on Real Estate Law, Vol. II, (edited by) G. Visintini, CEDAM, 2013.
– <\/em>Nonprofit entities: theoretical profiles of the taxation regime in Italy and abroad, in Proceedings of the conference Nonprofit and professionals: issues and proposals, Bocconi University of Milan, October 3, 2013.
– Reorganization operations, bilateral conventions and protection of the tax system: the DMC case opens another chapter in exit taxation, in Dir. Prat. Trib. Int., 2013\/2.
–<\/em> Fiscal federalism in the United States of America, in Dir. Prat. Trib., 2012\/5<\/em>.
– Taxation<\/em> of Intercompany Dividends under Tax Treaties and EU Law: Italy, in Maisto (editor), Taxation of Intercompany Dividends under Tax Treaties and EU Law, IBFD, 2012.
– International Cooperation in<\/em> Assessment and Collection, in The Concentration of Collection in Assessment (Proceedings of the conference held in San Remo on June 3 and 4, 2011, Padua, Italy, 2011.
– The<\/em> credit for taxes paid abroad (forthcoming edited by G. Moschetti): text of the lecture given at the international tax law meetings organized by the University of Padua.
– The<\/em> eligibility of credit for foreign taxes and the nondeductibility of manufactured payments in a decision of the Provincial Tax Commission of Reggio Emilia straddling tax avoidance and tax evasion, forthcoming in Riv. Dir. Trib., Part V.<\/em>
– The<\/em> taxation of income from currency transactions in the FOREX market between letter c-ter, quater and quinquies of Art. 67 tuir, in Financial instruments and taxation , no. 3, 2011, pp. 123<\/em>.
– The<\/em> CTP of Bergamo declares the incompatibility of the CFC regime with the provisions of conventions to avoid double taxation, in Financial Instruments and Taxation, 1\/2010.
–<\/em> The application of outbound withholding taxes on dividends in three rulings of the CTP of Pescara, in Dir. Prat. Trib. Int., 1\/2010, II, 537 (at www.dpti.it).
– The <\/em>emissions trading scheme: accounting and tax aspects, in Dir. Prat. Trib., 2010, I, 15<\/em>.
– Il <\/em>rimpatrio, in Lo scudo fiscale (edited by Studio Uckmar, Milano Finanza, Italia Oggi), Milan, 2009.
– Brief<\/em> critical notes on the Supreme Court’s interpretation of the taxation of severance pay in international cases, in Dir. Prat. Trib., 2009, II, 691.
– Handbook of <\/em>International Tax Law (with V. Uckmar and G. Corasaniti), Cedam, 2009.
– VAT\/GST<\/em> and Direct Taxes: How to Distinguish?, working paper for the conference VAT and Direct Taxation: differences and similarities organized by the University of Vienna, March 26-28, 2009, in Riv. Sc. Fin. Dir. Fin., 2009, I, 289 and in Value Added Tax and Direct Taxation: Similarities and Differences, edited by M. Lang-P. Melx-E. Kristofferson, Vienna, 2009.
– La<\/em> noci\u00f2n de establecimiento permanente en el comercio electr\u00f2nico, in Impuestos sobre el comercio internacional, 2008.
– Brief<\/em> notes on transfer of residence and entry of assets into the Italian tax sphere, in Dir. Prat. Trib., 2008, II, 33.
– The <\/em>OECD’s new proposals on mutual agreement procedures for resolving international tax disputes, in Proceedings of the conference celebrating 80 years of Diritto e Pratica Tributaria, Genoa, February 9-10, 2007.
– The<\/em> tax recognition of values recorded as a result of virtuous business combination transactions, forthcoming for Sole24Ore.
– The<\/em> new presumption of tax residence of Ires subjects, (co-authored with Corasaniti) in Dir. Prat. Trib., 2007, 97.
– Irap<\/em> and vat: two opposite taxes, in Dir. Prat. Trib., 2006,1287.
– Merger with<\/em> Abertis penalizes minority shareholders, in Italia Oggi, May 30, 2006.
– Irap issue returns to sender, in Italia Oggi, March 16, 2006<\/em>.
– The<\/em> Court of Justice and the most-favored-nation clause in the D. case. That is, about-face: international law prevails over EU law, in Dir. Prat. Trib. Int., 2005<\/em>, 1081.
– Letter<\/em> to the President of the European Court of Justice Concerning the Italian Irap and the European VAT, (with Oldman, Bird and Cnossen), in Dir. Prat. Trib. Int., 2005<\/em>, 358.
– Taxes on transfer of residence abroad,<\/em> in Corso di diritto tributario internazionale<\/em>, edited by V. Uckmar, Padua, 2005.
– The<\/em> protection of privacy in tax inspections<\/em>, in Code of Tax Inspections<\/em>, edited by V. Uckmar and F. Tundo, Piacenza, 2005.
– Outsourcing<\/em> and taxation, in ICC Legal Handbook on Global Sourcing Contracts, ICC publication No. 663, Paris, 2006.
– The<\/em> pros and cons of the Italian Irap, in Tax Notes International, May 2004, 639<\/em>.
– The<\/em> European Court of Justice rules on exit taxes: remarks about the freedom of establishment in the EU, in Dir. Prat. Trib. Int., 2004, 1139<\/em>.
– Irap<\/em>: some considerations pending the proposed repeal, in Dir. Prat. Trib., 2004, I, 1167<\/em>.
– Competition law between the<\/em> Constitution and EU law, in The Dialogue between the Courts, edited by Navarretta-Pertici, Pisa, 2004.
– The <\/em>regional tax on production activities, in Dir. Prat. Trib., III, 2003, 1045<\/em>.
– The<\/em> notion of residence in EU and domestic law, (co-author) in Corr. Trib., 2002, 3338<\/em>.
– The<\/em> final consumer’s standing in VAT matters, in Dir. Prat. Trib., 2002, II, 507<\/em>.<\/p>\n\n\n\n