calibrating the best defensive strategy for each individual case as a whole during the audit, considering how each case presents peculiarities that distinguish it from others and requires attention to detail in order to grasp on the one hand the possible inconsistencies emerging in the objections received from the defendants, and on the other hand the legal framework and the case law precedents that may be useful to the (new and unique) case;
preparing the necessary pleadings in defence of the taxpayer with the highest degree of personalisation in the light of all the elements of fact and law;
submitting requests for administrative suspension and requests for self-defence (for the benefit of both the assisted persons and, in the case of self-defence, the tax authorities themselves);
drafting appeals in the first instance (Provincial Tax Commission), in the second instance (Regional Tax Commission) and, where necessary in the interests of the clients, in the last instance (Supreme Court);
favouring and initiating (where it corresponds to the taxpayer's interest) assessment procedures with adhesion (through the presentation of the appropriate application to the Inland Revenue Agency), during which participation in meetings with Inland Revenue Agency officials is ensured (subject to representation by the assisted persons);
preparing, where appropriate, appeals also addressed to the Guarantor of Taxpayers. In particular, in the litigation phase, one or more members of the team of Studio Ciattaglia, Pellegrini & Partners (identified in each case on the basis of the subject matter of the dispute, in order to ensure the most appropriate specialist intervention) take on, individually or jointly, the role of taxpayer's advocate. In this role, the advocates of Studio Ciattaglia, Pellegrini & Partners are able to perform the most appropriate specialist intervention. Partners are able to carry out this task by taking care, with the utmost detail in fact and law, of the drafting of the appeals and the preparation of the relevant annexes (which are indispensable to prove the facts underlying the defensive arguments), drafting and discussing also the supplementary and illustrative pleadings, the replies to the administration's counter-deductions, the applications for judicial suspension, further taking care of the submission of appeals where necessary and attending the hearings before the competent Provincial and Regional Tax Commissions.
Studio Ciattaglia, Pellegrini & Partners can also offer, as a necessary complement to the assistance and representation service before Tax Commissions, with the same criterion of the intervention of the team member or members with the highest degree of specialisation in the area and providing the same types of services, assistance in the criminal-tax field, in the Public Prosecutor's Offices of the Courts competent to initiate independent criminal proceedings aimed at verifying the existence of various tax offences in the event of false declarations, omissions or irregularities in the keeping of compulsory records, tax fraud and all possible accessory cases.
