He advises Italian and multinational companies on their day-to-day tax matters, including corporate income taxes, local taxes and indirect taxation.
His M&A practice covers the tax aspects of extraordinary transactions, including mergers, demergers, spin-offs and transfers of business, as well as acquisition and disposal structures, management buyouts and leveraged buyouts. He also assists clients with transfer pricing matters, including the preparation of supporting documentation.
Sebastiano represents Italian and multinational companies during tax audits conducted by the Tax Authorities and in tax litigation proceedings, as well as in the settlement of disputes through alternative procedures. He also advises on the valuation of businesses and assets, including goodwill, trademarks and customer lists.
Latest Insights
- Advising a leading international commodities trading group in connection with a tax audit challenging the deductibility of costs related to wash-out, circle and string transactions, successfully concluded without any findings being raised by the Italian Tax Authorities.
- Advising a major global technology and retail company on the application of Country-by-Country Reporting requirements under EU Directive 2021/2101 and on the Italian abuse-of-law provisions in relation to an advance payment of a service fee between affiliated companies, across multiple jurisdictions.
- Advising a multinational food distribution group in connection with a tax audit challenging the transfer pricing applied to intercompany royalty payments, representing the company before the Italian Tax Authorities and determining the most effective defence strategy — a cross-border matter involving Italy and the United States.
- Advising a UK-listed investment fund on the application of the Italian domestic exemption from withholding tax on interest arising from investments in unlisted bonds issued by Italian companies, in a cross-border context.
- Advising a leading international renewable energy group on the tax-efficient reorganisation of its Italian renewable energy activities — managed through several SPVs — including the structuring of a holding company and a service company, in a cross-border engagement involving Italy and Switzerland.
- Advising a major multinational agribusiness group in the negotiation with the Italian Tax Authorities of transfer pricing assessments on intra-group guarantees spanning five fiscal years, through a combination of in-court and out-of-court settlement procedures.
- Advising an innovative space technology company on the withholding tax treatment applicable to interest on bonds issued by an Italian subsidiary, following the conversion of such bonds into equity instruments by the bondholders, and on the applicability of the self-correction procedure — a cross-border matter involving Italy, the UAE and the United States.
- Advising a Swiss industrial manufacturing group in connection with the assessment of a permanent establishment in Italy of the Swiss parent company and the identification of possible remedies, in a cross-border engagement involving Italy and Switzerland.
- Advising the shareholders of a leading Italian food company on the tax structuring of a majority investment by a private equity fund, including the design of the most tax-efficient structure and the planning of a generational handover.
- The Tax department, led by partner Sebastiano Sciliberto, has been consistently ranked in The Legal 500 for several years, reflecting its recognized expertise, technical excellence, and strong track record in advising clients on complex domestic and international tax matters.
- Client testimonials published by The Legal 500 further highlight the department’s reputation:
“We are very pleased to collaborate with this company, which stands out for its professionalism, reliability, and innovative approach. Their team brings deep expertise and a strong commitment to quality, consistently delivering results that add real value to our work together.”
“The individuals we work with truly stand out for their expertise, responsiveness, and collaborative spirit. They combine a deep understanding of the market with a pragmatic, solution-oriented approach that sets them apart from competitors.” - Sebastiano and his team won the “Italy Indirect Tax Law Firm of the Year” award at the at the 2026 ITR (International Tax Review) Europe Tax Awards.
- TAX AREA
Tax consultancy of ordinary nature
Tax advisor for multinational and Italian companies in respect of their day-to-day activity (corporate income tax, local tax and indirect taxes).
Mergers and Acquisitions and Taxation Group
Tax advisor in extraordinary transactions (mergers, demergers, spin offs and transfers of business), in the models and structures for acquisition and sale of investments, management buyouts and leveraged buyouts.
Transfer pricing
Tax advisor in transfer pricing issues, including the preparation of the supporting documentation.
Tax audits and litigations
Sebastiano represented several multinational and Italian companies during tax audits, and in tax litigations, or in settling them by means of alternative dispute resolutions.
- FINANCIAL AREA
Evaluation of businesses and tangible assets, like goodwill, trademarks and customers lists.
- CORPORATE GOVERNANCE AREA
Sebastiano is member of the Board of Statutory Auditors or Surveillance Body of several multinational and Italian companies, focusing on the corporate governance rules and on the lawfulness of the decisions made by the corporate bodies.
- Sebastiano holds a degree in Economics from the University of Rome, has been a member of the Italian Register of Chartered Accountants since 1992 and the Italian Register of Statutory Auditors since 1995, and speaks Italian and English.
- He serves on the Boards of Statutory Auditors and Supervisory Bodies of several Italian and multinational companies.