Toni Marciante is a senior associate in the Italian tax practice group.
He mainly advices on domestic and international tax law aspects, with particular emphasis on tax treatment of (i) M&A transactions, corporate reorganisations, private equity transactions; (ii) financial instruments, in particular withholding or capital gain tax obligations for financial intermediaries as well as financial transaction tax (FTT) obligations; (iii) real estate transactions. He regularly assists clients in connection with ruling requests, tax audits (often having tax criminal law ramifications), tax settlement procedures with the tax authorities and tax litigations in front of the Italian tax courts.
Of Italian mother tongue, he speaks English fluently and French.
Assisting an international bank on the opening of a direct account at Monte Titoli and the contextual qualification as Italian withholding tax agent in the frame of the implementation of a pan-European system aimed at centralising settlement of equities and bonds across the Eurozone (so-called Target2 Securities);
Assisting Italian branches of foreign banks in tax audits, assessments and settlement on transfer pricing matters (deemed lack of free capital), Italian source income realised on a cross-border basis and structured finance transactions;
Assisting an Italian multinational group in connection with an Euro 7bln multi-borrower, multi-jurisdiction and multi-facility refinancing transaction as well as on the cross-border re-organisation with possible impacts on tax group regime and tax attributes;
Assisting on tax aspects related to the combination of the telecommunication businesses of two major Italian mobile players and on the subsequent sale of frequencies and infrastructure assets divested as remedy to obtain clearance from the EU Commission;
Assisting an Italian telecommunication company in accessing the Italian patent box regime.