Francesco Spurio

Practice Areas

He is highly experienced in international taxation problems, Patent Box regimes and in the development of tax control frameworks for the attendance to the Italian Cooperative Compliance programme.

He has managed the ruling procedures of most relevant multinational enterprises, dealing with transfer pricing, interests, dividends and royalties problems.

Career

Francesco was part of the Advance Pricing Agreements Office from 2005 to 2016 where he served as head of the Milan office since 2011. This experience allowed him to gain in-depth expertise on unilateral and bilateral procedures in the areas of:

- Transfer pricing

- Determination of exit or entry values in case of transfer of residence

- Allocation of profits or losses to permanent establishments

- Prior assessment of the existence of the requirements, which constitute a permanent establishment

- Disbursement or receipt of dividends, interest, royalties and other income components

Since 2016, he has been assisting Italian and foreign multinational groups in international taxation from intercompany pricing to the achievement of APA and BAPA on complex issues.

In recent years, he has completed his experience dealing with the implementation of tax risk management tools (Tax Control Framework), assisting primary companies in dealing with the Collaborative Compliance Office, and has delved into complex issues in relation to Tax Credit regimes (Patent Box and Research & Development Credits).

Publications

He is regularly speaker at tax conferences and seminars on international tax matters and writes articles on most relevant Italian tax magazines as well as technical newspapers.