Paolo Franzoni

 Areas of expertise

• Tax Law
• International Tax Law
• Litigation and assistance with tax audits
• M&A
• Extraordinary operations
• Economic, financial and tax due diligence
• Assistance to multinational groups in external relations and in connection with management and internal management control requirements
• Asset protection plans
• Defense counseling in criminal proceedings (financial offences only)

 Professional Experience

• Mr. Franzoni holds a degree in Business Administration from Bocconi University, a law degree from the University of Milan and a degree “en derecho” from UCAM – Università Católica de Murcia (Spain).
• After an initial work experience in France, he began his professional career working with leading law firms in Milan and Modena; in 1991, he founded the Milan based firm Franzoni e Associati, of which he was the naming partner.
• He is specialized in tax consultating and litigation and provides services to many domestic and foreign clients, including mandates for, dealing with extraordinary operations such as LBOs, mergers, demergers, liquidations, contributions.
• In 2015 he joined Elexia lawyers & accountants as founding partner.

 Education

• 2013, Attended a Specialization Program in Sports Law
• 2007, Law degree with honors, Milan State University
• 1988, Degree with honors (cum laude) in Business Administration, Bocconi University of Milan

 Professional quaifications

• 2012, Registered with the Bar Association of Milan
• 1991, Registered with the Association of Certified Chartered Accountants and Auditors

 Publications

• The definition of permanent establishment in income tax, EGEA, 2014.
• Publications for the online review “Football and Finance”
• Several publications for “Investor’s” review.
• Obligation to state reasons for notices of assessment and failure to enclose the documentation referred to therein, in Bollettino Tributario di Informazioni, 2007, no. 19.
• The concept of permanent establishment for income tax purposes and the concept of fixed establishment for VAT purposes, in Tax Bulletin, 2007, No. 6.
• Transfer of business and transfer of the tax relationship concerning VAT from the transferor to the transferee, in Bollettino Tributario di Informazioni, 2006, n. 23.
• Definition of residence: predominance of substantial aspects, in Bollettino Tributario di Informazioni, 2006, n. 21.
• Definition of individual residency for income tax purposes, in the Tax Information Bulletin, 2006, no. 20.
• Bankruptcy agreement: exemption from penalties and interest for late payments, in Il Fallimento, 2005, n. 7.
• Dual Income Tax (DIT). Challenging the tax agency’s interpretation of the application of anti-avoidance provisions after June 30, 2001, in the Tax Information Bulletin, 2005, no. 22, is open to question.
• Advance payment of IRES and IRAP in mergers by incorporation between companies with share capital, specifying the case of the retroactive merger as per Article 172, paragraph 9 of the Consolidated Law on Income Tax (TUIR), in Bollettino Tributario d’Informazioni, 2005, no. 14.
• Exemption from sanctions and interests for individuals subject to bankruptcy proceedings, in Il Fallimento, 2004, n. 2.
• Composition Procedure. Who is eligible, in Economics, 15.11.2003, p. 25.
• Dividends, a rapacious administration. The sting is also on physical individuals, in Economy, 18.10.2003.
• Dividend revolution. Companies will pay more, in Economics, 11.10.2003.
• Reimbursement of registration tax paid upon filing of a demerger deed, in Corriere Tributario, 2000, no. 5.
• Tax liability in the partial sale of a company, in Le Società, 1991, no. 9.
• Capital gains. The new tax on capital gains, in Le Società, 1991, no. 7.
• Convention with France against double taxation, in Le Sociétés, 1991, no. 4.