Tax & Customs Criminal Law

A criminal tax allegation can jeopardize the future of both a company and an individual. Such charges often arise from complex business transactions, disputed interpretations of tax legislation, or the practical difficulty of complying with constantly evolving regulations. With over 40 years of experience, we have developed in-depth expertise in the most sensitive areas of criminal tax liability, including transfer pricing, permanent establishments, foreign corporate residence, and tax fraud. We work closely with leading accounting and tax advisory firms to provide an integrated, strategic defense. We regularly assist individuals, companies, corporate groups, entrepreneurs, legal representatives, and professionals, both Italian and international, ensuring effective courtroom defense as well as ongoing out-of-court legal advice.

Legal Assistance for Individuals, Companies, and Professionals

We provide legal assistance and criminal defense to Italian and foreign companies, professionals, sole proprietors, and individuals with international operations involved in proceedings concerning tax, fiscal, and customs offenses. Our expertise ranges from traditional tax evasion cases to highly complex matters of international taxation, including transfer pricing, permanent establishments, foreign control of Italian companies, corporate reorganizations with tax implications, voluntary disclosure procedures, and tax regularization strategies.

Integrated Criminal Defense and Strategic Coordination

Tax criminal law requires a seamless integration of criminal law expertise and advanced tax knowledge. Drawing on more than 40 years of experience, we know that systematic cooperation with highly qualified accountants and tax advisors is essential to building defenses that fully address all relevant dimensions: criminal, civil, administrative, and accounting. This approach is particularly crucial in complex proceedings involving parallel tax audits, preventive seizures, confiscation measures, or voluntary disclosure procedures. In such cases, every step must be carefully planned to safeguard assets and ensure business continuity. Over time, we have developed a solid network of technical and tax consultants and work closely with leading accounting and tax law firms, ensuring coordinated and effective defenses even in the most delicate disputes.

Specific Areas of Practice

Tax and Fiscal Offenses

Fraudulent tax returns through the use of invoices or other documents for non-existent transactions;
Fraudulent tax returns through other deceptive schemes;
Inaccurate tax returns and failure to file tax returns;
Issuance of invoices or other documents for non-existent transactions;
Concealment or destruction of accounting records;
Failure to pay VAT and certified withholding taxes;
Improper tax offsetting;
Fraudulent removal of assets to evade tax payment;
Tax fraud;
Offenses under Legislative Decree No. 74/2000;
Transfer pricing, permanent establishments, foreign corporate residence;
Money laundering and self-laundering;
Voluntary disclosure procedures and application of statutory grounds for non-punishability in criminal matters.

Customs and Excise Offenses

Smuggling and unlawful handling 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 manufacture of alcohol and alcoholic beverages;
Evasion of assessment and payment of excise duties on alcohol and alcoholic beverages;
Tampering with devices, seals, markings, or official control instruments.

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

Analysis and implementation of organization, management, and control models aimed at preventing tax offenses;
Internal auditing and compliance programs;
Court defense of companies charged under Legislative Decree 231/2001;
Assistance and coordination with Supervisory Bodies (ODV).

Frequently Asked Questions

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

As a rule, voluntary disclosure is only available if no formal tax investigations or assessments are already pending. However, each situation has its own specific features: we carefully assess your case to identify the most appropriate and legally compatible regularization strategies.

How are preventive tax seizures handled?

We develop immediate and targeted strategies to protect assets and ensure business continuity, coordinating applications for the release of seized assets with the overall defense strategy.

Can you work with my trusted technical advisors?

Yes. Once the case has been assessed, we can effectively collaborate with technical and tax consultants of your choosing.