TAX INSIGHTS
Practical guides for your decisions, alongside Lucian’s events and press appearances. Search for a question or explore articles by category.
A foreign company may face Romanian tax questions without incorporating a local subsidiary. A permanent establishment assessment examines actual activities, premises and people’s roles, together with the applicable treaty.
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A cross-border payment should be assessed by reference to the income, its recipient and the rules applicable between the countries. A tax residence certificate matters, but does not by itself establish every condition for favourable treatment.
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A holding structure makes sense when it addresses a clear need for organisation, investment or continuity. The tax treatment of each step needs to be considered alongside its legal and operational effects.
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Tax residence is not determined solely by the number of days spent in a country. Relocation calls for a review of both countries’ rules, personal and economic ties, and any applicable double taxation treaty.
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Transaction records should explain both what the parties agreed and what actually happened. Contracts, invoices and evidence of performance are more useful when they provide a coherent explanation of the economic purpose.
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Tax due diligence before an acquisition helps identify risks that may affect the price, contract and first steps after completion. The review should reflect the business and transaction structure, rather than rely on a tax clearance certificate alone.
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