Introduction

Michele leads our Italian practice, providing strategic tax advice on cross-border transactions, transfer pricing, and tax litigation.

Michele Milanese has a significant experience in financial and corporate taxation as well as on the tax aspects related to structured finance, private equity, global banking, project finance, asset finance, energy and securitization transactions.

Michele regularly assists important Italian and international clients in pre-litigation, litigation, tax compliance and transfer pricing. He is the author of several publications in Italian and international journals and held conferences and lectures on legal and fiscal issues.

  • A Luxembourg clear energy US and Luxembourg fund in relation to tax and transfer pricing advice for investments made in Italy, the Netherlands and the UK.
  • Italy’s national development bank on tax assistance in certain advisory activities relating to DLT bond issuance schemes and specific tax regulations.
  • A major infrastructure player on the partial demerger of their holding arm (shareholdings in dealerships and related financial relationships) in favor of a new Italian company.
  • An Italian multinational food company with global reach on internal tax advice related to the review and analysis of the tax treatment applicable to certain derivative financial instruments entered into by the company.
  • A leading Italian infrastructure company in the context of litigation activities related to a tax claim received by the company on registration tax. 
  • A major supplements producer in the context of the litigation with the Italian Tax Authority concerning the application of the withholding tax exemption applied to the dividends paid by the Italian subsidiary to the UK parent company.
  • A major UK bank on the tax analysis of their equity finance and long positions business in Italy. 
  • A platform designed to manage and integrate retail operations across online and physical stores in relation to a new potential Italian VAT matter concerning the fiscal treatment of omnichannel retail transactions.
  • A New York-based innovator in AI-driven commerce on certain regulatory and tax advice related to the onboarding of an Italian service provider and the granting of stock option equity.
  • A fund manager on Luxembourg and Italian legal and tax assistance in relation to the restructuring of their current company structure.