Italy

PwC

Via Monte Rosa, 91

20149 Milan

Italy

Tel: +39 02091605804 – 348.2344239

Fax: +39 0291605499

Email: paolo.comuzzi@it.pwc.com

Website: pwc.com/taxcontroversy

Paolo has more than 16 years of professional experience practising both with PwC and with other international tax firms.

Paolo holds both a degree in economics from Bocconi University in Milan and in law from State University and he is a qualified Italian certified public accountant (CPA) and is registered tax expert within the Italian Ministry of Justice since 1991.

Paolo has gained a strong reputation in the market providing tax advice on relevant transactions and assisting on a continuing basis major domestic and international market players on tax compliance and fulfillment of tax requirements.

Paolo has significant expertise in mergers and acquisitions (including assisting Mondavi in the acquisition of Antinori Group), having participated in a number of important domestic and cross-border projects and tax litigations (for Italian, German, Swiss and Swedish companies also).

Paolo is on the board of auditors of many domestic and multinational companies and he is admitted as a member of the Italian centre for criminal tax law.

Paolo speaks Italian (native) and English

Cordeiro Guerra & Associati

Via De' Bardi 28

50125 Florence

Italy

Tel: +39 055 2001611

Foro Buonaparte 12

20121 Milan

Italy

Tel: +39 02 76023340

Email: roberto@cordeiroguerra.it

Website: www.cordeiroguerra.it

Roberto Cordeiro Guerra is the founding partner of Cordeiro Guerra & Associati, established in 2003 with its main offices in Florence and Milan.

Roberto, who may rely on the support on 20 highly-skilled tax lawyers and chartered accountants, has 30 years of experience in assisting individuals, sportspeople and artists, companies and multinationals in tax litigations, tax audits and settlements with the Italian tax authorities in a wide range of issues, including transfer pricing, direct tax issues, VAT and other indirect tax issues. He also assists taxpayers in all of the administrative procedures with Italian and foreign tax authorities aimed at finding settlements or filing rulings.

Roberto advises Italian and foreign taxpayers on the tax aspects of corporate reorganisations, private equity, real property acquisitions, M&A, and financial transactions, among other things, providing a full expertise also in international and foreign tax issues.

He is a lawyer (avvocato) and full professor of international tax law at the University of Florence. Roberto teaches international, national and EU tax law in many post-graduate programmes. He is director of the post-graduate programme in criminal tax law at the University of Florence.

He is co-founder of Tax Law Quarterly (Rivista Trimestrale di Diritto Tributario) and permanent member of the Scientific Committee of Diritto e Pratica Tributaria Internazionale, one of the most important international tax journals. Roberto authored the book Diritto Tributario Internazionale. Istituzioni (International Tax Law. Institutions), published in 2012.

He graduated summa cum laude from the University of Florence in 1984 and from 1987 was admitted to practice in Italy and enrolled in the College of Advocates of Florence (Albo degli Avvocati di Firenze).

Roberto speaks Italian and English.

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 is a CPA (dottore commercialista) and tax partner with Studio Tributario e Societario (Deloitte Italy), part of the global Deloitte member firm network. Before joining Deloitte, Matteo worked with Arthur Andersen as well as a tax consultancy firm based in Milan and Genoa.

Matteo has more than 20 years' experience in national and international tax, group reorganisations, mergers and acquisitions, tax and corporate consultancy for multinational companies. 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 audit, 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, leisure and entertainment, oil and gas, banking and insurance, environmental services, construction, defence, aviation, pharmaceutical, chemical, information technologies, communication 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 dottore commercialista (CPA), revisore contabile (statutory auditor), consulente tecnico del giudice (court consultant), earned a degree in economics from Genoa University as well as serving in the Italian Navy as a lieutenant.

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

Matteo speaks Italian and English.

Studio Tributario e Societario – Member of Deloitte Touche Tohmatsu Limited

Deloitte Italy

Via XX Settembre 1

00187 Roma

Italy

Tel: +39 06 48990834

Email: edellavalle@sts.deloitte.it

Website: www.deloitte.it

Eugenio della Valle is a tax law full professor at La Sapienza Rome State University as well as a tax lawyer and tax partner with Studio Tributario e Societario (Deloitte Italy), a Deloitte member firm. Before joining Deloitte, Eugenio worked with the Italian desk of a major international law firm.

Eugenio has more than 20 years' experience in national and international tax, group reorganisations, mergers and acquisitions, and tax and corporate consultancy, serving multinational companies. 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 under the jurisdiction of the tax courts. He also advises on all aspects of tax audit, 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 across a wide range of industries.

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

Eugenio regularly speaks at domestic and international tax conferences, as well as before the Revenue Agency, Tax Police and at other public bodies' requests. He is a member of the editorial boards/scientific committees of the most important Italian tax journals and is the author of more than 100 publications.

Eugenio speaks Italian and English.

Studio Tributario e Societario – Member of Deloitte Touche Tohmatsu Limited / Deloitte Italy

Via Tortona 25

20144 Milan

Italy

Tel: +39 (0)2.83324111

Email: sfedele@sts.deloitte.it

Website: www.deloitte.it

Stefano Fedele is a lawyer and tax partner with Studio Tributario e Societario (Deloitte Italy), a member of the global Deloitte network of member firms.

Stefano has more than 19 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 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

Largo Angelo Fochetti 29

00154 Rome

Italy

Tel: + 39 06 57127220

Mobile: +39 335 6075317

Email: carlo.romano@it.pwc.com

Website: pwc.com/taxcontroversy

Carlo is PwC's tax controversy and dispute resolution leader in Rome. In this role, Carlo is in permanent contact with the tax authorities

Carlo has an extensive experience in managing tax audits, tax litigation cases, negotiating settlements and advising multinational clients on defensive and tax dispute strategies. He has significant ruling experience assisting in the preparation of advance pricing agreements (APAs) and assisting in disputes relating to transfer pricing.

He has gained significant experience in representing and assisting clients before the Italian Supreme Court and before the Court of Justice of the European Union (CJEU).

Carlo is a professor at the former Scuola Superiore dell'Economia e delle Finanze (now Scuola Nazionale dell'Amministrazione, SNA) and scientific director of the LLM in international tax law. Carlo is representing the Italian branch in the General Council of the International Fiscal Association and is board member of the Italian branch. He is a member of the International Tax Committee of the Business Consultants Association and of the Tax Lawyers' Association of Rome. He is the worldwide co-founder of the Young IFA Network (YIN) and he is the representative for Italy.

Carlo is author of various publications in international, European and comparative tax law and is a speaker for several courses and conferences in Australia, Austria, Belgium, Germany, Hungary, Italy, Poland, Russia, Spain, the Netherlands and the US.

He is doctor in international and comparative tax law (PhD cum laude from the University of Groningen in the Netherlands) and was formerly a visiting scholar at New York University (NYU).

Tremonti Vitali Romagnoli Piccardi e Associati, Studio legale e fiscale

Via Crocefisso, 12

20122 Milan

Italy

Tel: (+39) 02 58313707

Fax: (+39) 02 58313714

Email zoppini@virtax.it

Website: www.virtax.it

Giancarlo is a partner at Tremonti Vitali Romagnoli Piccardi e Associati Studio Legale e Fiscale. He acts as attorney in fiscal cases and as counsel in tax criminal cases.

Giancarlo received his degree in law cum laude from the University of Bologna. He is admitted to the Milan Bar and to the Supreme Court (Corte di Cassazione), is a registered auditor and has completed a four-year course for officers in full permanent service – Tax Police Academy.

Giancarlo was an officer of the Tax Police for three years, where he was in full permanent service engaged in taxation and judicial matters. From 1991, he became engaged in professional practice in one of the most important Italian tax law firms, before moving to legal and tax consultancy firm Studio Tremonti e Associati in 1993 and being made partner in 2000. Giancarlo has had numerous tax law essays published in scholarly reviews.