Italy

Deloitte Italy

Piazza della Vittoria 15/34

16121 Genoa

Galleria San Federico 54

10121 Turin

Italy

Tel: +39 010 5317811

Email: mcostigliolo@sts.deloitte.it

Website: www.deloitte.it

Matteo Costigliolo, Deloitte Italy, is a tax partner who previously worked with Arthur Andersen and a tax consultancy firm based in Milan and Genoa.

Matteo has over 20 years of experience in national and international tax, group reorganisations, mergers and acquisitions, tax and corporate consultancy for multinational enterprises. He specialises in tax controversy and litigation, specifically assisting clients, usually large and medium-sized companies, in administrative proceedings in front of the tax authorities and matters heard by the tax courts. He also gives advice on all aspects related to tax audits, assessment and collection procedures and on administrative and criminal penalties, as well as other administrative procedures such as rulings or tax claims, for both Italian and foreign companies.

Matteo's clients are many of the largest Italian and international companies operating in a wide range of industries including shipping, logistics, automotive, steel, leisure and entertainment, oil and gas, banking and insurance, environmental services, construction, defence, aviation, pharmaceutical, chemical, information technologies, communications and telecommunication, professional sports, large retailers and food and beverage.

Matteo is member of the Statutory Auditors Board of Medium/Large Companies. He is a chartered accountant, statutory auditor and court consultant. He earned a degree in economics from Genoa University and served the Italian Navy as lieutenant.

Matteo regularly speaks about tax issues at domestic and international conferences and workshops in Italy, also on the request of the Revenue Agency and other public bodies. He regularly contributes articles concerning significant tax issues to specialised technical publications.

Deloitte Italy

Via XX Settembre 1

00187 Rome

Italy

Tel: +39 06 48990834

Email: edellavalle@sts.deloitte.it

Website: www.deloitte.it

Eugenio della Valle, Deloitte Italy, is a tax partner, a tax law professor at Sapienza University of Rome, and a tax lawyer (Avvocato tributarista). Prior to joining Deloitte, Eugenio worked with the Italian desk of one of the major international law firms.

Eugenio has over 25 years' experience in national and international tax, group reorganisations, mergers and acquisitions, tax and corporate consultancy for multinational enterprises. He specialises in tax controversy and litigation, specifically assisting clients, usually large and medium-sized companies, in administrative proceedings in front of the tax authorities and matters ruled by the tax courts. He also gives advice on all aspects related to tax audits, including assessment and collection procedures and on administrative and criminal penalties, as well as other administrative procedures such as rulings or tax claims, for both Italian and foreign companies.

Eugenio's clients are some of the largest Italian and international companies operating in a wide range of industries.

Eugenio is member of the Rome Bar, as well as member the Italian Tax Law Professors' Association. He earned a degree in law from Sapienza University of Rome and served the Italian Tax Police as a lieutenant.

Eugenio regularly either speaks at (or organises) domestic and international tax conferences and workshops in Italy, also on the request of the Revenue Agency, Tax Police and other public bodies. He is a member and sole director of the editorial boards and scientific committees of the most important Italian tax journals. He has written more than 100 publications, spanning from articles to books.

Eugenio speaks Italian and English.

Deloitte Italy

Via Tortona 25

20144 Milan

Italy

Tel: +39 (0)2 83324111

Email: sfedele@sts.deloitte.it

Website: www.deloitte.it

Stefano Fedele, Deloitte Italy, is a lawyer and tax partner with over 20 years' experience in domestic and international taxation. Stefano specialises in tax litigation and tax controversy, including representing clients in Italian tax, civil, criminal and administrative courts proceedings. He assists clients with restructuring and business planning operations and tax audits, and advises on administrative procedures of the Italian tax authorities, as well as all aspects of assessment procedures and administrative and criminal penalties.

Stefano assists clients with matters from audit to litigation, including every step of the administrative process. His litigation experience spans the full spectrum of issues, from VAT to corporate tax claims for both Italian and foreign companies. With respect to tax claims related to individuals, he advises clients relative to all aspects of matters that are before the Tax Court of I degree, the Tax Court of II degree and the Supreme Court.

Stefano serves many of the largest Italian and international companies, doing business across a wide range of industries including pharmaceutical, chemical, information, communication and telecommunications, logistics, automotive, hospitality, gas, banking and insurance, laundry and home care, large retailers and food.

Stefano has written articles for specialised Italian tax magazines and is engaged as a speaker at conferences.

He earned a Master of Tax Law degree from INFOR (Milan, 1995/1996) and was admitted to the Bar in 1998. Stefano is also qualified to represent clients in front of the Italian Supreme Court.

PwC

Via Monte Rosa, 91

20149 Milano

Italy

Tel: +39 02 91605807

Email: valentino.guarini@it.pwc.com

Website: www.pwc.com/taxcontroversy

Valentino Guarini is partner at PwC's tax controversy and dispute resolution network. He is based in the Milan office in Italy.

Valentino has achieved 21 years of experience inside the PwC network dealing with tax controversies. He also developed his experience through a wider range of activities in M&A, corporate restructurings, domestic and international tax advising.

Valentino and his team specialise in tax controversy and dispute resolution, handling assistance in the course of tax audits, as well as pre-litigation phases (settlements and rulings) and litigations before the tax courts.

He is an attorney-at-law before the tax courts and serves a wide range of clients (MNEs) in dealing with tax controversies, as well as providing tax advice on both domestic and international tax matters. He serves and advises clients in a variety of sectors with particular focus on consumer and industrial products, fashion and luxury, and pharmaceutical sectors.

Valentino is member of the International Taxation Commission of the Chartered Tax Consultants Council of Milan. He graduated both in economics and in law.

PwC

Via Monte Rosa, 91

20149 Milano

Italy

Tel: +39 02 91605005

Email: marco.lio@it.pwc.com

Website: www.pwc.com/taxcontroversy

Marco Lio is an associate partner in PwC's tax and legal practice in Italy, focusing on tax and transfer pricing advisory, dispute resolution and tax policy areas.

Before joining PwC in 2015, Maco served with the Italian tax authority where he achieved 13 years of experience. He became the chief officer in charge of the large business taxpayers units in Rome and, subsequently in Milan.

In his role as chief officer of the large business taxpayers unit, he was in charge of the organisation working on risk analysis and detection procedures, as well as focused on tax audits and consequent tax settlement procedures.

During his service with the Italian tax authority, Marco also advised the Italian Central Directorate of Assessment of the Italian Tax Authority, on drafting official guidelines, tax regulations and tax rulings.

Relying on his previous work experience and on the skills he developed during his service with the Italian Tax Authority, Marco supports the activities of PwC in the area of tax controversy and dispute resolution, with particular reference to cross-border and domestic direct taxation.

Marco is actively engaged in the implementation of the projects related to the Cooperative Compliance Regime, adopted by Italy in 2015, and the outcomes of the BEPS project.

PwC Tax and Legal Services

Largo Angelo Fochetti 29

00154 Rome

Italy

Tel: +39 06 57127202

Mobile: +39 335 6075317

Email: carlo.romano@it.pwc.com

Website: www.pwc.com/taxcontroversy

Carlo Romano is a partner of PwC tax and legal services and he is the tax controversy and dispute resolution leader in Italy.

He is a tax lawyer with 20 years of experience. He is qualified to appear before the Supreme Court and has a PhD in international and comparative tax law (cum laude) from the University of Groningen, Netherlands. His areas of specialisation include domestic, European and international business taxation and transfer pricing.

Carlo has been involved in several leading national and international cases and has a broad experience in dealing with tax litigations – also before the Italian Supreme Court and the European Court of Justice – and with pre-litigation settlements. He has gained a broad experience in APA negotiations and ruling practices.

He writes for various Italian and international tax journals and he is the author of various publications in international tax law. His book 'Advance Tax Rulings and Principles of Law' (IBFD, 2002) is a milestone in the academic studies about rulings and APAs.

He has been a professor of tax law in various Italian universities, at the SSEF Scuola Superiore dell'Economia e delle Finanze (now SNA – Scuola Nazionale dell'Amministrazione) and visiting researcher at New York University. He regularly teaches in several courses for the officials of the Ministry of Finance and of the Revenue Agency as well as at LUISS and Bocconi Universities.

PwC

Via Monte Rosa, 91

20149 Milano

Italy

Tel: +39 91605038

Email: dario.sencar@it.pwc.com

Website: www.pwc.com/taxcontroversy

Dario Sencar is an associate partner in PwC's tax and legal practice in Italy, focusing on tax and transfer pricing advisory, dispute resolution and tax policy areas.

Dario joined PwC in 2015, after having served for 16 years with the Italian tax authority, where he became the chief officer in charge of the special tax audits unit, focusing on transfer pricing, attribution of profits to permanent establishments, (with specific focus on banking branches), mergers and acquisitions, tax avoidance, beneficial ownership, detection of aggressive tax planning transactions (both domestic and cross-border), such as post tax hedging, foreign tax credit generators, dividend washing through stock exchanges and other forms of structured finance.

As part of his service with the Italian tax authority, he also provided, on regular basis, advisory and support to the large taxpayers unit offices throughout Italy. He worked, on regular basis, with the Central Directorate of the Italian tax authority with respect to tax regulations and tax rulings. The main areas of his activities were: IAS/IFRS; exit taxation; the financial transaction tax (FTT), reform of the Italian cross-border tax legislation; general anti-avoidance rule (GAAR); and the allowance for corporate equity.

Relying on his previous work experience and on the skills he developed during his service with the Italian tax authority, Dario supports the activities of PwC in the area of tax controversy and dispute resolution, with particular reference to cross-border and domestic direct taxation.

Dario is actively engaged in the implementation of projects related to the Cooperative Compliance Regime, adopted by Italy in 2015, and the outcomes of the BEPS project.

Dario has represented the Italian tax authority at the OECD as part of the ATP steering group (from 2010 to 2015) and the BEPS project (namely: Action 1 on the digital economy; Action 2 on hybrid mismatches; Action 3 on CFCs and Action 4 on interest expenses deduction).

Studio Tremonti Romagnoli Piccardi e Associati

Via Crocefisso, 12

20122 Milan

Italy

Tel: +39 02 58313707

Fax: +39 02 58313714

Email: zoppini@virtax.it

Website: www.virtax.it

Giancarlo Zoppini is a practicing lawyer and partner at Studio Tremonti Romagnoli Piccardi e Associati. Based in the Milan office of the firm, he specialises in tax litigation. His areas of expertise include settlements, advance ruling proceedings, legal defence in fiscal cases, providing assistance in tax audits, pre-litigation, litigation, and taxpayer representation in cases before the Italian Revenue Agency. He also acts as counsel in criminal tax cases.

Since joining Studio Tremonti Romagnoli Piccardi e Associati in 1993 (then called 'Studio Tremonti e Associati'), Giancarlo has been engaged in professional practice with the firm and became a partner on January 1 2000.

Giancarlo received his degree in law (summa cum laude) from the University of Bologna in 1991. He passed the state exam at the first session (1993-1994) for the Court of Appeals in Milan and was admitted to the Milan Bar in 1995. A year later in 1996, he was admitted to the Accountant Auditors Association. Since 2007, he has regularly defended cases before the Supreme Court.

In 1988, Giancarlo graduated from a four-year degree course for officers in full permanent service at the Italian Tax Police Academy in Bergamo. From 1988 to 1991 he served as an officer in full permanent service with the Italian Tax Police engaged in tax and criminal matters. From 1991 to 1993, he was engaged in professional practice with another leading Italian firm, Falsitta e Associati.

From 1991 to date, he has published numerous articles and tax law essays in Italian scholarly reviews.