Francesco has an extensive experience in international taxation with particular reference to Advance Pricing Agreements. His experience over the years has expanded into the area of tax risk management through advanced tools including the Cooperative Compliance regime
Experience
Francesco was part of the Advance Pricing Agreements Office from 2005 to 2016 where he served as head of the Milan office since 2011. This experience allowed him to gain in-depth expertise on unilateral and bilateral procedures in the areas of:
- Transfer pricing
- Determination of exit or entry values in case of transfer of residence
- Allocation of profits or losses to permanent establishments
- Prior assessment of the existence of the requirements, which constitute a permanent establishment
- Disbursement or receipt of dividends, interest, royalties and other income components
Since 2016, he has been assisting Italian and foreign multinational groups in international taxation from intercompany pricing to the achievement of APA and BAPA on complex issues.
In recent years, he has completed his experience dealing with the implementation of tax risk management tools (Tax Control Framework), assisting primary companies in dealing with the Collaborative Compliance Office, and has delved into complex issues in relation to Tax Credit regimes (Patent Box and Research & Development Credits).
Education
He holds a degree in economics and a Master’s degree in Quantitative Finance. He is a member of the Order of Chartered Accountants of Milan and the Register of Auditors, and a member of the International Tax Commission of the Order of Chartered Accountants of Milan.
He regularly writes technical articles in specialized magazines and newspapers and participates as a lecturer in training courses, seminars and conferences.
