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.
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.
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).
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).
Il quadro RW, novità per Unico18
Novità fiscali no. 1/2019, International and EU Tax Law, SUPSI (Switzerland).
Accertamento e rapporti con l'Estero
Chapter in «Pillole d'accertamento e contenzioso», Giuffrè.
Le opere d'arte: quadro generale dell'eventuale tassazione della plusvalenza
Co-written with Avv. M. Faggioli, published in Bollettino Tributario no. 17.
Aspetti critici della nuova procedura di collaborazione volontaria
Analysis of Italy's voluntary disclosure procedure, published on Diritto Bancario.
Il riporto delle perdite fiscali nella fusione di società
Case comment, published on Diritto Bancario.
Patent box non più per i marchi d'impresa
On the regulatory evolution of the patent box relief, published on Diritto Bancario.
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.
Direct taxes
SAF Lombardia — online Mini-Master "Blockchain and Artificial Intelligence".
New international tax rules — the regime for inbound workers
Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.
Recent case law and practice on individual tax residency
Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.
Voluntary correction of tax returns and its criminal-law implications
Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.
Switzerland: tax fundamentals and exchange of information
Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.
Alternative dispute-resolution tools; the tax defence lawyer 2.0
Ordine dei Dottori Commercialisti ed Esperti Contabili di Milano.
Alternative forms of financing: an opportunity for professionals and businesses
Ordine dei Dottori Commercialisti ed Esperti Contabili di Verona.
Transfer pricing and the 2017 OECD Guidelines
Ordine dei Dottori Commercialisti ed Esperti Contabili di Bergamo.
The new digital tax-litigation process
Ordine dei Dottori Commercialisti ed Esperti Contabili di Milano.
Voluntary Disclosure: the international and domestic context
Sondrio Bar Association.
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.
Updates to the 2025 OECD Model Tax Convention — Art. 9, intra-group financial transactions and interest deductibility
SUPSI, Manno (Switzerland).
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.
Capital gains, dividends, interest and royalties
Ca' Foscari University of Venice, IBATAX first-level master's programme, 7th ed.
The foreign tax credit and issues relating to employment income earned abroad
University of Turin, Advanced Course in International and European Taxation.
Trust, Organization, Functions and Contracts (in English)
LUISS Business School, training programme for the Guardia di Finanza at its General Command.
Passive income and capital gains
Ca' Foscari University of Venice, IBATAX first-level master's programme, 6th ed.
Transfer Pricing
University of Bergamo, Advanced Tax Law course.
VAT
University of Bergamo, course preparing candidates for the Labour Consultants' qualifying examination.
Passive income and capital gains
Ca' Foscari University of Venice, IBATAX first-level master's programme, 5th ed.
BEPS Action 15, Multilateral Instrument for Tax Treaties
University of Bergamo, PhD programme in Business and Law.
Taxation of Interest and Royalties (in English)
Ca' Foscari University of Venice, Treviso campus, International Tax Law course.
Permanent establishment and passive income under international double-taxation treaties
Second-level master's in Tax Law, LUISS, Rome.
The disclosure of undeclared foreign assets in Italy: the 2018 rules
SUPSI, Manno (Switzerland).
Post-voluntary-disclosure tax monitoring (the RW form) and anti-money-laundering requirements (overview)
SUPSI, Manno (Switzerland).
International Tax Law: procedural rules (APAs and rulings)
Advanced Course for International Corporate Counsel, 2nd ed., University of Bergamo.
Group accounting and consolidated financial statements
University of Bergamo, Accounting course.
Income from land, employment income, investment income, miscellaneous income
University of Bergamo, Tax Law course.
The Abuse Concept in International Tax Law (in English)
University of Bergamo, International and EU Tax Law course.
Abuse of Rights (in English)
Vienna University of Economics and Business (WU).
Italy Tax Alert (in English)
Vienna University of Economics and Business (WU).
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
- a.brignoli@amtaxlegal.com
- Phone
- +39 035 211918
- linkedin.com/in/brignoli