Manufacturing company, ICT transfers to Italy

A Japanese multinational company operating in the precision automotive components sector, with manufacturing facilities in Asia and a commercial hub in Düsseldorf. Its Italian subsidiary, an S.r.l. employing around one hundred and fifty people and operating a plant in the Turin area, is entering a phase of expansion: the launch of a new line of components for electric vehicles requires the transfer of technological know-how from the parent company and the strengthening of local management.

The Japanese headquarters identifies three key figures to be transferred to the Piedmont plant, with assignments ranging from two to four years:

• A Japanese plant director from the Osaka headquarters, with spouse and two school age children
• A Japanese process engineer from the same headquarters, with spouse accompanying
• A German financial controller from the Düsseldorf hub, without accompanying family members

In this case, the Law Firm would structure a coordinated transfer project managing the three individual pathways in parallel – each with its own specific requirements – within a common timeline defined by the plant’s operational deadline.

1. Coordinated immigration strategy
   • Mapping of the three pathways and identification of the appropriate residence title: ICT permit for manager (director), ICT permit for specialist (engineer), EU free movement (German controller)
   • Preparation of the two ICT applications before the Immigration Single Desk: secondment letters from the parent company, detailed job descriptions consistent with the requested ICT category, documentation on the group’s corporate structure
   • Coordination with the Italian Consulate in Tokyo for the visa applications of the two Japanese employees, including certified translation of documentation and management of consular timelines
   • Management of residence permits for family reasons for the director’s family unit, including work authorization for the spouse
2. Tax planning
   • Analysis of the Italy Japan and Italy Germany Double Taxation Conventions for the correct allocation of taxing rights over remuneration and benefits for each employee
   • Verification of the requirements for access to the impatriates regime for each of the three employees and preparation of the relevant applications
   • Structuring of remuneration packages in compliance with Italian tax law: separation between taxable components and exempt or preferentially taxed benefits
   • Activation of social security coverage certificates pursuant to the Italy Japan bilateral agreement and EU regulations for the German employee, preventing double contributions
3. Operational relocation
   • Identification of three properties in the Turin area compliant with housing suitability requirements for ICT permits, including negotiation of lease agreements
   • School enrolment for the two minors: identification of the international school and preparation of enrolment documentation with recognition of Japanese school qualifications
   • Obtaining the Italian tax code, opening bank accounts, registration with the local municipality and registration with the Italian Revenue Agency for each employee and family member
   • Registration with the National Health Service and selection of a general practitioner for each family unit

“The transfer of key personnel is always the critical link in the expansion of a production plant. In this case we had to coordinate three transfers within a deadline linked to the launch of a new line: a delay on a single permit would have compromised the entire plan. Our HR department in Osaka had no visibility over the complexities of the Italian system, and we at the Piedmont subsidiary did not have the expertise to manage Japanese visas and cross border taxation in parallel. The Law Firm built a plan that aligned every step, managing relations with the Consulate and the Italian authorities while providing us with weekly updates. We did not lose a single day on the timeline.”