Tax & Customs Criminal Law

A criminal tax charge can jeopardize the future of a company or an individual. Behind these accusations often lie complex business transactions, controversial regulatory interpretations, or difficulties in managing ever-changing rules. With over 40 years of experience, we have developed unique expertise in the most sensitive aspects of criminal liability in tax matters, such as transfer pricing, permanent establishments, foreign corporate residence, and tax fraud. We work closely with leading accounting and tax law firms to offer an integrated and strategic defense. We regularly assist individuals, companies, corporate groups, entrepreneurs, legal representatives, and professionals, both Italian and foreign, ensuring both courtroom defense and out-of-court counsel.


We provide legal assistance and defense to Italian and foreign companies, professionals, and sole proprietors, as well as individuals with international operations involved in proceedings for tax, fiscal, and customs offenses. Our expertise ranges from classic tax evasion cases to the most complex issues of international taxation: transfer pricing, permanent establishments, foreign control over Italian companies, corporate reorganizations with tax implications, voluntary disclosure, and tax regularization.

Criminal tax law requires a perfect synergy between criminal law expertise and tax knowledge. With over 40 years of experience, we are certain that systematic collaboration with top-tier accountants and tax experts is crucial for building defenses that consider all aspects: criminal, civil, administrative, and accounting. This approach is particularly essential in complex proceedings involving parallel investigations, preventive seizures, confiscations, or voluntary disclosure procedures. In these cases, every move must be precisely planned to protect assets and ensure business continuity. Over the years, we have developed a solid network of technical and tax consultants and collaborate with leading accounting and tax law firms, ensuring coordinated and effective defenses even in the most delicate disputes.

Specific Areas of Practice

We have always provided legal assistance and defense in the following areas:

Tax and Fiscal Offenses

Fraudulent tax returns through the use of invoices or other documents for non-existent transactions, fraudulent tax returns through other artifices, inaccurate tax returns and omitted tax returns, issuance of invoices or other documents for non-existent transactions, concealment or destruction of accounting records, failure to pay VAT and certified withholdings, improper tax offsetting, fraudulent removal of assets to avoid payment of taxes, tax fraud, offenses under Legislative Decree 74/2000, transfer pricing, permanent establishments, foreign corporate residence, money laundering, self-laundering, voluntary disclosure, and the application of non-punishability clauses in criminal law.

Customs and Excise Offenses

Smuggling and theft of manufactured tobacco, counterfeiting, excise duty violations, evasion of assessment or payment of excise duties on energy products, sale of manufactured tobacco without authorization or purchase from unauthorized sellers, clandestine manufacturing of alcohol and alcoholic beverages, criminal association for the clandestine manufacturing of alcohol and alcoholic beverages, evasion of assessment and payment of excise duties on alcohol and alcoholic beverages, tampering with devices, seals, and marks.

Administrative Liability of Entities (Legislative Decree 231/2001) and Tax Compliance

Analysis and implementation of organization, management, and control models for the prevention of tax crimes, internal auditing, legal defense for companies charged under Legislative Decree 231/2001, and Supervisory Bodies (ODV).

Frequently Asked Questions

Can I benefit from voluntary disclosure if I am already under investigation?

Voluntary disclosure is typically only available if no formal tax inquiries or assessments by the authorities are already underway. However, every situation has its unique aspects: we will carefully evaluate your case to identify the most suitable and compatible regularization strategies for your legal position.

How are preventive tax seizures managed?

We develop immediate strategies for the protection of assets and business continuity, coordinating requests for the release of assets with the overall defense strategy.

Can you collaborate with my own trusted technical consultants?

Certainly. After reviewing the situation, we can also work effectively with the technical consultants of your choice.

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