Tax Advisor (Dottore Commercialista) · LL.M. in International Taxation (Vienna University)

Andrea Brignoli

Domestic and international taxation, tax litigation and corporate crisis management, between professional practice and academic work, in Bergamo and Milan.

Study, think, understand… redo, then write.

My approach

A path shaped by professional practice and research

I graduated in Economics of Institutions and Financial Markets from the University of Bergamo (1999), with an exchange term at Copenhagen Business School, and in 2013 earned an LL.M. in International Taxation from the Vienna University of Economics and Business (WU), with a thesis on treaty shopping and international tax planning. Before turning to private practice, I completed my military service at the Guardia di Finanza Academy in Rome, later serving as an officer at the Guardia di Finanza's Alpine School in Predazzo.

I am a Tax Advisor and Statutory Auditor. I work with the Court of Bergamo on insolvency proceedings and vacant estates, and I have been listed in the National Register of Judicial Administrators since 2017; I also act as court-appointed technical expert on transfer pricing for the Lombardy Regional Tax Court (second instance).

Since 2020 I have practised as a chartered accountant with AM | Tax | Legal, based in Bergamo and Milan, which draws on an independent network of accountants and lawyers specialised in tax law and corporate crisis, including its criminal-law aspects. I was previously a partner at Lucchini e Associati ACBGroup and, for 18 years before that, an associate at Studio Lucchini ACBGroup, also in Bergamo.

I was appointed a member of the study committee (Ministerial Decree of 20 July 2023) established at the Cabinet of the Minister of Justice (Ministerial Decree of 5 May 2023) and tasked with drafting a definitive legislative proposal on the criminal law of corporate crisis and insolvency (the so-called "Commissione Bricchetti").

I teach at universities and professional bodies: I lecture at the University of Bergamo and in master's courses at LUISS, Ca' Foscari Venice and SUPSI (Switzerland); I have also lectured for the Ordini dei Dottori Commercialisti ed Esperti Contabili and Bar Associations of Milan, Bergamo, Verona, Sondrio, Teramo and Asti, as well as for SAF Lombardia. I have been a member of the International Tax and Law Committee of the Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo and of the International Fiscal Association (Italian branch) since 2013.

I was appointed by the Courts of Palmi and Bergamo as judicial administrator of consulting companies under Legislative Decree 231/01, and I am listed in the Ministry of Justice's register of corporate-crisis practitioners and in the regional roster of negotiated-crisis-settlement experts held by the Milan Monza Brianza Lodi Chamber of Commerce. I speak Italian, English, Spanish, French and German.

I am also a member of the Pastoral Council of the Parish of San Tommaso Apostolo in Bergamo and, since 2021, a member of the Board of Auditors of Fondazione Credito Bergamasco.

Where I work, from planning to defence

I work with resident and non-resident individuals, medium and large enterprises and a credit institution, from diagnosing the tax position through to, where necessary, defence in litigation.

International taxation

Cross-border tax planning, application of double-taxation treaties, transfer pricing and the qualification of permanent establishments.

Tax litigation

Assistance with tax audits, assessments and proceedings before the Tax Courts of Justice at every level.

Expert opinions and technical consultancy

Sworn expert opinions and technical consultancy, for private parties and courts, in civil matters and in tax-crime and bankruptcy-offence proceedings, including transfer pricing.

Extraordinary transactions

Tax due diligence, structuring of mergers and acquisitions, corporate reorganisations and real-estate transactions with significant tax implications.

Corporate crisis

Bankruptcy trusteeships and judicial administration, drafting of restructuring plans and assistance in insolvency proceedings.

Prevention of tax offences

Building tax-compliance models and assisting in proceedings related to tax and corporate offences.

Writings on tax law

A selection of contributions published over the course of my professional and academic work.

Forthcoming

Art. 9 in the Commentary on the 1976 Italy–Switzerland Double Taxation Convention

Contribution to the commentary edited by Prof. Vorpe and Prof. Greggi, SUPSI (Switzerland).

2022

Le restrizioni delle libertà fondamentali europee e gli obblighi di monitoraggio fiscale in Spagna e Italia

Novità fiscali no. 10/2022, International and EU Tax Law, SUPSI (Switzerland).

2019

Il quadro RW, novità per Unico18

Novità fiscali no. 1/2019, International and EU Tax Law, SUPSI (Switzerland).

2018

Accertamento e rapporti con l'Estero

Chapter in «Pillole d'accertamento e contenzioso», Giuffrè.

2018

Le opere d'arte: quadro generale dell'eventuale tassazione della plusvalenza

Co-written with Avv. M. Faggioli, published in Bollettino Tributario no. 17.

2017

Aspetti critici della nuova procedura di collaborazione volontaria

Analysis of Italy's voluntary disclosure procedure, published on Diritto Bancario.

2017

Il riporto delle perdite fiscali nella fusione di società

Case comment, published on Diritto Bancario.

2017

Patent box non più per i marchi d'impresa

On the regulatory evolution of the patent box relief, published on Diritto Bancario.

2013

Treaty Shopping and International Tax Planning

Contribution in «Limits to Tax Planning», LINDE Verlag, Vienna.

I also served as case-law editor ("massimatore") for the Lombardy Tax Commissions' Law Reports for the years 2012 to 2017 (Giuffrè Editore and Istituto Poligrafico - Zecca dello Stato).

Talks given at professional bodies and schools

A selection of talks given in recent years.

2025

Direct taxes

SAF Lombardia — online Mini-Master "Blockchain and Artificial Intelligence".

2024

New international tax rules — the regime for inbound workers

Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.

2022

Recent case law and practice on individual tax residency

Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.

2022

Voluntary correction of tax returns and its criminal-law implications

Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.

2020

Switzerland: tax fundamentals and exchange of information

Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.

2019

Alternative dispute-resolution tools; the tax defence lawyer 2.0

Ordine dei Dottori Commercialisti ed Esperti Contabili di Milano.

2019

Alternative forms of financing: an opportunity for professionals and businesses

Ordine dei Dottori Commercialisti ed Esperti Contabili di Verona.

2018

Transfer pricing and the 2017 OECD Guidelines

Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.

2017

The new digital tax-litigation process

Ordine dei Dottori Commercialisti ed Esperti Contabili di Milano.

2015

Voluntary Disclosure: the international and domestic context

Sondrio Bar Association.

2013

Steps preceding a bankruptcy filing and reconstructing the bankruptcy estate's liabilities

Criminal Bar Association of Eastern Lombardy.

Lectures and seminars at Italian and Swiss universities

A selection of lectures given in university courses, master's programmes and doctoral programmes, in Italian and in English.

2026

Updates to the 2025 OECD Model Tax Convention — Art. 9, intra-group financial transactions and interest deductibility

SUPSI, Manno (Switzerland).

2021

Employment income, cross-border commuters and the foreign tax credit under Art. 165 of the Italian Income Tax Code

University of Turin, Advanced Course in International and European Taxation.

2021

Capital gains, dividends, interest and royalties

Ca' Foscari University of Venice, IBATAX first-level master's programme, 7th ed.

2020

The foreign tax credit and issues relating to employment income earned abroad

University of Turin, Advanced Course in International and European Taxation.

2019

Trust, Organization, Functions and Contracts (in English)

LUISS Business School, training programme for the Guardia di Finanza at its General Command.

2019

Passive income and capital gains

Ca' Foscari University of Venice, IBATAX first-level master's programme, 6th ed.

Since 2018, annually

Transfer Pricing

University of Bergamo, Advanced Tax Law course.

Since 2018

VAT

University of Bergamo, course preparing candidates for the Labour Consultants' qualifying examination.

2018

Passive income and capital gains

Ca' Foscari University of Venice, IBATAX first-level master's programme, 5th ed.

2018

BEPS Action 15, Multilateral Instrument for Tax Treaties

University of Bergamo, PhD programme in Business and Law.

2018

Taxation of Interest and Royalties (in English)

Ca' Foscari University of Venice, Treviso campus, International Tax Law course.

2018

Permanent establishment and passive income under international double-taxation treaties

Second-level master's in Tax Law, LUISS, Rome.

2018

The disclosure of undeclared foreign assets in Italy: the 2018 rules

SUPSI, Manno (Switzerland).

2016

Post-voluntary-disclosure tax monitoring (the RW form) and anti-money-laundering requirements (overview)

SUPSI, Manno (Switzerland).

2016

International Tax Law: procedural rules (APAs and rulings)

Advanced Course for International Corporate Counsel, 2nd ed., University of Bergamo.

2016

Group accounting and consolidated financial statements

University of Bergamo, Accounting course.

From 2015 to 2021

Income from land, employment income, investment income, miscellaneous income

University of Bergamo, Tax Law course.

2014

The Abuse Concept in International Tax Law (in English)

University of Bergamo, International and EU Tax Law course.

2012

Abuse of Rights (in English)

Vienna University of Economics and Business (WU).

2012

Italy Tax Alert (in English)

Vienna University of Economics and Business (WU).

2011

A Framework for Loss Relief in Italy, France and Spain (in English)

Vienna University of Economics and Business (WU).

Get in touch

Address
Via Torquato Tasso 109, 24121 Bergamo, Italy
Email
a.brignoli@amtaxlegal.com
Phone
+39 035 211918
LinkedIn
linkedin.com/in/brignoli