Tax Litigation

LEXIA boasts a high and well-established level of specialization in tax law, thanks to dedicated internal departments (tax, tax enforcement, tax advisory, administrative law, and public finance), all skillfully led and coordinated by cofounder and managing partner Avv. Prof. Alessandro Dagnino, one of the most renowned and respected tax lawyers at the national level.

We have a long series of innovative case histories that have impacted tax law and business, with cases also handled before the Court of Cassation and the Constitutional Court. We provide consultancy and assist clients in all phases of the tax assessment procedures conducted by the Italian Revenue Agency and/or the Guardia di Finanza.

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Intro Our Services Experience in all tax procedures
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Our Services

Our services include:

  • Advising and defending taxpayers during inspections carried out by the Italian Revenue Agency;

  • Litigation related to tax assessments before the first and second instance tax courts throughout Italy;

  • Litigation before the Court of Cassation – Tax Section;

  • Out-of-court and judicial settlements on tax assessments;

  • Advising and defending taxpayers in criminal proceedings arising from tax assessments (in collaboration with the client’s criminal lawyer).

Experience in all tax procedures

We also have extensive experience in all tax procedures, including those based on:

  • Financial investigations;

  • Analytical-inductive tax presumptions;

  • Fully inductive tax presumptions;

  • ISA (Synthetic Indicators of Tax Reliability);

  • Issues related to M&A transactions (mergers and acquisitions);

  • Tax issues concerning corporate groups;

  • Carousel fraud schemes;

  • False invoices and fictitious interposition;

  • Abuse of tax law;

  • Abuse of international tax treaties;

  • Transfer pricing;

  • Permanent establishment and tax residence;

  • Denial of tax incentives.

Our twenty years of expertise cover all taxes assessed by the Italian Revenue Agency, including:

  • IRES (corporate income tax);

  • VAT;

  • IRAP (regional tax on productive activities);

  • IRPEF (personal income tax);

  • Registration tax;

  • Tax penalties.

Duties collected by the Customs and Monopolies Agency

Taxes on gaming and betting
We have extensive experience in providing advice and assisting clients during audits and tax assessments carried out by the Italian Customs and Monopolies Agency (ADM). We represent leading national and international operators in the gaming and betting sector, including their affiliates (CTDs – Data Transmission Centres), in disputes concerning gaming and betting taxes (Single Tax on Gaming and Betting – Imposta Unica sui Giochi e le Scommesse, IUC – and the Single Tax Levy – Prelievo Erariale Unico, PREU). We also assist trade associations of gaming and betting operators and their members.

Customs and excise duties
We provide assistance and represent oil companies in tax litigation concerning excise duties, having handled particularly complex and innovative cases, including preliminary references before the Court of Justice of the European Union. Our clients include international trading companies, which we advise on customs-related legal matters.

Assistance in local taxation matters

The tax law department is specialized in local taxation, including municipal, provincial, and regional taxes. This particular — and often less familiar — area of tax law, if misinterpreted, can lead to significant and complex tax assessments and disputes. Thanks to this specialization, we advise and represent national and multinational companies before tax courts and the Supreme Court (Corte di Cassazione) in high-value cases concerning local taxes, including:

  • TOSAP (Public Space Occupation Tax)

  • TARI (Waste Tax)

  • IMU (Municipal Property Tax)

Our clients include major economic operators active in sectors such as parking management, renewable energy (wind and solar), hospitality, project financing, and waste management.

Assistance in parafiscal taxation matters

Another area of tax law in which we have developed strong expertise is that of quasi-tax levies — revenues that are not formally collected as taxes but can, in substance, be considered as such, in accordance with the principle of substance over form. In this field, our firm is among the pioneers in Italy.

The cases we have handled include, among others:

  • Fees for official health inspections carried out to verify compliance with food safety regulations and European legislation on animal health and welfare, collected by health authorities from companies operating in the agri-food sector;

  • Taxes on the “technical extension” of gaming concessions, collected by the Monopolies Agency from companies managing bingo halls;

  • Road tolls adopted by municipalities for car circulation.

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Privacy
Awards
TopLegal Award 2023
Alessandro Dagnino, professionista dell'anno nella categoria Tax
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Legalcommunity Tax Awards 2023
Categorie: Litigation, Private clients & Wealth management e Tax restructuring
TopLegal Awards 2022
Lexia vincitore nella categoria Studio dell’anno Sud
Alessandro Dagnino finalista nella categoria Tax Litigation
I migliori Avvocati e i migliori Studi Legali – Milano Finanza 2021
Categoria: Tax Dispute
I migliori avvocati e i migliori studi legali del territorio – Capital 2021
Categoria: Diritto Fiscale Sud e Isole
TopLegal Awards 2020
Vincitore nella categoria Studio dell’anno Sud
Finalista nella categoria Tax contenzioso
TopLegal Awards 2019
Vincitore nella categoria Studio dell’anno Sud
Legalcommunity Tax Awards 2020
Finalista nelle categorie: Tax contenzioso, Tax penale, Tax real estate
Other practices
Betting & Gaming
We provide our clients with specialized legal and tax assistance and consultancy in the field of betting & gaming.
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Criminal tax law and criminal economic law.
The firm assists and represents companies and individuals in complex proceedings concerning criminal tax law and economic criminal law. In particular, this includes tax offenses under Legislative Decree No. 74/2000, corporate crimes, bankruptcy offenses, as well as crimes against the Public Administration. The criminal tax and economic law team boasts decades of experience in the field, with numerous successes in cases of significant media relevance.
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Private Law
The firm, with a dedicated team, provides legal advice and assistance to companies, entrepreneurs, and individuals operating in the business world.
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Tax Restructuring
We provide consultancy and assistance with business crisis in order to resolve disputes and mitigate the impact of a business crisis or tax debt. LEXIA's team protects the client's interests, ensure compliance with relevant laws, and work towards favorable resolutions to address financial difficulties.
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Public Finance
With its specialized focus on Public Finance, LEXIA provides assistance in disputes before the relevant courts for matters of accountability and consultancy in the interest of both public entities, local authorities, and companies.
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Private Tax
LEXIA provides highly specialized tax services to individuals and families with complex estate, focusing on estate planning, international tax matters, and full compliance with both Italian and foreign tax regulations. Our goal is to manage, protect, enhance, and efficiently transfer wealth in a fully compliant and tax-efficient manner.
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Tax Advisory
We provide comprehensive tax advisory services, assisting our clients on tax matters related to their commercial and strategic projects, and ensuring highly qualified and up-to-date support on the complex national and international tax environments. Our team of experts collaborates closely with professionals from the corporate and financial law departments, ensuring an integrated approach that meets business needs and optimizes their tax structures efficiently and in compliance with applicable regulations. Moreover, we offer specialized tax advice to high-net-worth individuals, supporting them in all tax law matters related to the transfer of tax residence to or from Italy. This includes tax optimization for entering or leaving the country, ensuring compliance with both Italian and foreign regulations for personalized and strategic tax planning.
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Tax Collection Disputes
The team specialized in tax collection law defends taxpayers against the Revenue Agency - Collection (ADER) and private municipal collection agencies.
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Tax & Accounting Services

LEXIA boasts deep and recognized expertise in the field of accounting and tax assistance, providing companies with a comprehensive range of services that meet accounting and tax compliance needs with precision and timeliness. We offer support for corporate bookkeeping and for the preparation and submission of tax returns, ensuring that every aspect of tax compliance is managed in full accordance with the relevant regulations.

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Customs advisory and litigation
We represent clients in all stages of customs litigation, both administrative and tax, providing assistance in cases of audits, sanctions, seizures, or confiscations. We offer support in preparing customs rulings (BTI, IVO) and managing inspection procedures. In M&A transactions and international reorganizations, we also conduct targeted due diligence to assess the customs compliance of the target company and recommend any corrective actions. Our department works in close synergy with the tax litigation and tax advisory teams, providing integrated, high value-added legal assistance.
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