Tax Advisory and Transfer Pricing Services

The new business models, the digitalisation, the geopolitical and economic context, as well as public policies are transforming the global taxation landscape. In the context of increased scrutiny by tax authorities, the taxpayers need a broad understanding of their tax compliance obligations and new approaches to preventing and resolving tax disputes.

Tax Advisory and Transfer Pricing Services

Through our tax advisory services, we provide advice and strategic guidance on a wide range of tax-related matters for individuals and companies. These services are designed to help clients navigate the complexities of tax legislation, identify tax opportunities and minimize risks.

Our tax & transfer pricing consultancy services are based on 3 essential pillars:

A high level of understanding of client’s business, and the problems they face. Thus, we focus on providing business solutions to customer problems and challenges, where taxation is an important part, but it is not the only component of the solution.
A comprehensive identification of tax risks, in order to offer solutions for risk management by using a full range of tax procedures. We have a high degree of knowledge of tax procedures, and how accessing them can help clients manage situations of uncertainty and risk.
Solutions built on knowledge of business models and best practices at national and international level, adapted to the specifics of each client to ensure compliance with constantly changing legislative and tax requirements, which optimize tax burden and minimize exposure to risks.

Tax consultancy on

Corporate income tax (e.g. analysis of the applicable tax system, implications of the minimum turnover tax or global minimum tax, analysis of the deductibility of some expenses, tax implications of foreign investments in Romania, including analysis of permanent establishment risk in Romania, analysis of the place of effective management, etc.).
VAT (e.g. analysis of the VAT treatment applicable to complex transactions with goods and services; implications of VAT in (re)structuring of supply chains, reorganizations, transfer of going concern, mergers and acquisitions; application of VAT exemption to intra-community supplies, exports of goods, and chain supplies; analysis of fixed establishment risk for non-resident taxpayers; analysis of the obligation to register for VAT purposes; implications of RO e-Invoice, RO e-Transport and SAF-T reporting).
Income tax and social contributions (e.g. treatment of various components of salary packages, application of stock option plans, tax implications of organizing the activity in different forms, taxation of capital gains, etc.).
International mobility services (e.g. taxation of posted employees, determination of tax residence, etc.)
Withholding tax on non-residents’ income obtained from Romania (e.g. interest, royalties, services, commissions, capital gains, application of double taxation treaties and European directives, etc.).

Tax compliance

Tax registration in Romania of non-residents, for VAT purposes (direct registration or through fixed establishment for non-residents), corporate income tax (permanent establishments), social contributions (non-resident employers), income tax from salaries (posted employees or Romanian employees employed by non-resident employers), withholding tax (non-resident taxpayers obtaining income from Romania).
Calculation and declaration of taxes due in Romania by non-residents (e.g. allocation of profits to permanent establishments and calculation of corporate income tax, calculation and declaration of VAT for activities in Romania or for supplies for which Romania is the country of registration in the OSS, calculation of payroll tax and social contributions due in Romania, etc.).
Assistance for Romanian taxpayers: analysis and preparation of tax documents (evaluation and preparation of documents necessary for the correct and timely submission of tax returns and other reports required by tax legislation), monitoring deadlines (strictly following deadlines for submitting returns and other tax documents to avoid penalties and maintain compliance with tax requirements), tax health checks (checking and reviewing tax documents for errors or discrepancies, ensuring they are corrected before they are formally filed), advice and guidance (providing advice and guidance on legislative changes and tax updates to ensure compliance and to maximize available legal tax benefits), reports and communication (providing periodic reports and relevant communications related to tax compliance, informing clients of their tax obligations and possible legislative changes).

Assistance in tax audits, tax disputes or other tax procedures:

Assistance and representation during unannounced inspections, documentary checks, tax inspections, personal situation checks or anti-fraud controls, including assistance in discussions with the tax inspection team, support in quickly solving inspectors’ requests, preparation of explanatory notes, points of view, representation in final discussions with tax authorities.
Assistance in tax litigations, by assisting in drafting appeals against tax decisions, collaborating with tax litigation lawyers in initiating court actions, drawing up expert reports, as an expert appointed by a party to a tax litigation, when deciding to request expert evidence as a proof in court.
Assistance in other tax procedures, such as: preparation and submission of applications for issuing individual tax rulings or for obtaining advance pricing agreements, for more tax certainty in complex transactions or for transactions with material impact, assistance in applying for tax debt instalments, assistance in obtaining various certificates, etc.

Transfer pricing assistance

Assistance in preparing transfer pricing files (TPD), for large taxpayers who have the obligation to prepare transfer pricing documentation annually, by the deadline for submitting the annual corporate income tax return, or for medium and small taxpayers, following a request during the tax inspection, or as part of the tax compliance strategy, as well as assistance in country-by-country reporting.
Advising on transfer pricing setup or in restructuring of value chains, for Romanian groups of companies, as well as for international groups of companies.
Preparation of expert reports, as an expert appointed by one party to a tax litigation, in transfer pricing disputes, when the expert evidence is considered part of the strategy to support arguments in a tax dispute, in compliance with the rules of independence.