RSS logo
Home > Our services > Tax > International Taxation

Audit

Outsourcing - Accounting & Payroll

Tax


Legal

Recently visited pages

International Taxation

International investments have increased dramatically in the recent years, owing to the integration of national economies and the growth and diversification of the operations performed by multinational enterprises in a multitude of countries. This process has brought about a higher complexity of taxation issues posed to both multinational enterprises and tax administrations.

International Tax Structuring

Our integrated network of tax specialists is highly experienced in addressing complex international taxation aspects and structuring your business in a tax efficient manner, including implementation of the contemplated structure.

If your objective is:

  • To expand your business to new jurisdictions
  • To optimise the overall tax position of your business
  • To mitigate any local tax authority challenges
  • To design and implement your treasury function in a global manner

…Then we can:

  • Design an international structure for your business to address your operational objectives in a tax efficient manner
  • Advise on tax efficient holding company locations
  • Advise on profit repatriation and efficient exit solutions
  • Suggest optimal finance and treasury solutions for your business
  • Advise on international tax aspects of business restructuring
  • Identify tax efficient solutions for intellectual property migration to address operational changes in your business structure
  • Provide assistance in the implementation of structuring solutions.

EU Tax Legislation

Romania’s accession to the EU brought significant changes in our legislation, some of the main areas which have been affected being direct and indirect taxation, environmental protection, Labour Law and Intellectual Property Law. However, the most direct and immediate impact on Romanian companies has been felt at the level of tax legislation.

Our tax specialists are experienced in advising clients on various issues deriving from the EU tax legislation, such as:

  • EU tax opportunities for our clients
  • Compliance with relevant provisions of EU law
  • Assistance on legal actions against local tax authorities and litigation before local courts and the European Court of Justice.

Withholding Tax

Non-residents obtaining revenues from Romania (such as interest, royalties, services, dividends, commissions, revenues derived from liquidation of a Romanian legal entity) are subject to a 16% withholding tax (“WHT”) in Romania.

Our tax experts can advise you on any options apt to diminish the non-resident’s tax exposure in Romania, by applying the provisions of either the relevant EU Directives, as the case may be, or the relevant Double Taxation Treaties, if the conditions required by law are met.

Moreover, we can assist you with:

  • finding solutions for reimbursement of the WHT paid in Romania in excess of the WHT rate provided in the Double Taxation Treaties;
  • obtaining the certificate attesting the payment of the WHT in Romania, based on which the non-resident may claim tax credit / tax exemption in its country of residence.

Permanent Establishments

Permanent establishment is a special tax concept which designates in principle the taxable presence of a company in a country other than its country of residence. Thus, a permanent establishment is defined as a fixed place through which the activity of a non-resident is conducted, fully or partially, either directly or through a dependent agent.

We are ready to assist our clients in structuring their investment in Romania, by implementing a structure which fits best their interests (permanent establishment, branch, joint venture, limited liability company or joint-stock company).

Contact us