Romania

Bucharest, February 11, 2026: The High Court of Cassation and Justice has recently upheld a decision of the Timisoara Court of Appeal, with significant relevance for transfer pricing disputes based on the re-qualification of the functional profile of a company within a multinational group from independent producer to producer under the full control of the group. It has been confirmed that elements specific to the operation of a multinational group, such as providing support services by global cooperation structures or the existence of common directors, do not prove the existence of a transaction between the parent company and the controlled entity that would justify reconsidering the functional profile of the company, even in cases where the controlled entity experienced periods of losses. Specifically, although the tax authorities invoked the existence of an unwritten understanding – not reflected in invoices or contracts - based on which the audited company was allegedly controlled by the group, acting in concert, with the aim of making sure the company continued to operate at a loss, which would result in the entire activity of the entity concerned (including that carried out with independent third parties) being regarded as that of a contract manufacturer, the evidence produced, including a complex tax expert report, did not reveal the existence of such an understanding. The court confirmed that an adjustment cannot be based on a presumed understanding. On the contrary, to make an adjustment, it is first necessary to identify and delineate the transaction to be adjusted. In the absence of an identified and delineated transaction that would justify the adjustment, the court established that the challenged acts were issued through the incorrect application of the provisions of Article 11 of the Fiscal Code, in the sense that an additional tax base was established by considering the transactions carried out with independent parties. Since similar situations have been frequent in the recent years in Western Romania, the case is highly important. NNDKP, through its Timisoara Office, has been involved in all phases of the litigation, providing integrated legal and tax services in a mixed team that included Partner Eva Forika, Head of NNDKP Timișoara Office, Senior Associate Ion Loga, Tax Director Sorin Mociofan, from NNDKP Timișoara Office, as well as Tax Partner Marius Ionescu, Co-Head of NNDKP Tax Advisory Services.   *** About NNDKP Nestor Nestor Diculescu Kingston Petersen (“NNDKP”) is a promoter of business law in Romania, being acknowledged as a pioneer of the Romanian legal market. NNDKP offers full service and integrated legal and tax advice to companies from diverse industry sectors. Over the past 35 years, NNDKP lawyers have assisted and represented clients in milestone transactions and projects that have shaped the evolution of the Romanian business community. NNDKP represents Romania in some of the most important international professional alliances - Lex Mundi, World Services Group, International Attorneys Club - and is a founding member of SEE Legal and Three Seas Legal Alliance. The firm is constantly top ranked in all practice areas by the renowned international guides Chambers & Partners, Legal 500 and IFLR 1000. In 2025 NNDKP became a 7-time winner of the prestigious “Romania Law Firm of the Year” award at the Chambers Europe Awards gala and was named “Romania Firm of the Year” by Benchmark Litigation and “Romania Patent Firm of the Year” by Managing IP.

Lexters, in consortium with the Belgian law firm Strelia, is proud to announce its role as legal counsel for the Romanian State, through the Ministry of Finance, in a landmark legal dispute against the pharmaceutical consortium Pfizer Inc. and BioNTech Manufacturing GmbH. The litigation, currently pending before the Francophone Court of First Instance in Brussels, involves a claim for approximately €615 million. The dispute originates from the centralized EU COVID-19 vaccine procurement framework and concerns Romania's decision to contest the delivery and payment of approximately 28 million surplus vaccine doses. This mandate represents one of the most significant public-sector litigations in Central and Eastern Europe, involving complex intersections of: EU Procurement: Interpreting the multi-state vaccine purchase agreements negotiated by the European Commission. International Contract Law: Addressing cross-border obligations undertook in unprecedented global pandemic conditions. Intellectual Property: Analyzing the complex IP rights associated with mRNA production technology and how these proprietary frameworks impact the contractual delivery and production obligations. Following the first procedural hearing in Brussels, a comprehensive calendar has been established, involving six phases of written submissions. The Lexters-Strelia team is leading the strategic defense, focusing on the validity of the contractual mechanisms and the specificities of the Romanian context within the broader EU framework. Given the high financial stakes and legal complexity (high-stakes, cross-border, EU involvement in formation of the contract), a first verdict could be reached in a few months, though the exact timing depends on the court’s workload. As this is the first instance, the judge may still request more evidence or reopen debates on specific legal points if necessary. By handling this landmark case, Lexters continues to demonstrate its capability to act as a legal powerhouse for sovereign clients and multinational corporations alike, providing clarity and confidence in high-stakes cross-border litigation. Media coverage of the case In Romania: MediaFax interview Romania Libera Press Coverage Antena 3 Interview In international press: Euractiv TVP World Romania Insider

Bucharest, February 5, 2026: Nestor Nestor Diculescu Kingston Petersen (NNDKP) advised Holcim Romania on the acquisition of Uranus Pluton SRL, a granite quarry operator active since 2004 in Tulcea county. NNDKP assisted Holcim Romania at every stage of the transaction, from conducting due diligence on the target and its mining operations to advising on the negotiation of the share sale and purchase agreement, as well as drafting and reviewing the relevant contractual documentation. Ruxandra Bologa, Partner and Co-Head of the Corporate/M&A and Energy and Natural Resources practices, coordinated the legal assistance provided in the transaction. Ruxandra was supported by Emanuel Flechea, Senior Managing Associate, and Georgiana Surdu, Associate, from the same practices, as well as Vlad Tanase, Partner in the Real Estate practice. “We are happy to have had the opportunity to assist Holcim Romania in a new acquisition on the construction materials market, strengthening its market position and diversifying its portfolio of products and solutions. We are also delighted to have supported Holcim throughout the process, contributing to the company’s sustainable growth plans, and we thank them for their trust in NNDKP’s team and for our excellent collaboration so far”, declared Ruxandra Bologa, Partner. With more than 35 years of experience in the market, NNDKP lawyers provide integrated and specialized assistance in all areas of law covered by transactions and regulatory projects, helping to identify bespoke solutions and strategies for each client. Over the past three decades, NNDKP’s Energy and Natural Resources team has built an impressive portfolio of successful projects, including first-of-their-kind initiatives in Romania and matters involving novel regulatory aspects. The team’s expertise, their top-tier service, and the complexity of the projects they have handled have been recognized by specialized international publications, with NNDKP lawyers ranking at the top in the most recent editions of the legal guides Chambers & Partners, Legal 500 and IFLR 1000. *** About NNDKP Nestor Nestor Diculescu Kingston Petersen (“NNDKP”) is a promoter of business law in Romania, being acknowledged as a pioneer of the Romanian legal market. NNDKP offers full service and integrated legal and tax advice to companies from diverse industry sectors. Over the past 35 years, NNDKP lawyers have assisted and represented clients in milestone transactions and projects that have shaped the evolution of the Romanian business community. NNDKP represents Romania in some of the most important international professional alliances - Lex Mundi, World Services Group, International Attorneys Club - and is a founding member of SEE Legal and Three Seas Legal Alliance. The firm is constantly top ranked in all practice areas by the renowned international guides Chambers & Partners, Legal 500 and IFLR 1000. In 2025 NNDKP became a 7-time winner of the prestigious “Romania Law Firm of the Year” award at the Chambers Europe Awards gala and was named “Romania Firm of the Year” by Benchmark Litigation and “Romania Patent Firm of the Year” by Managing IP.  

Bucharest, January 30, 2026: Nestor Nestor Diculescu Kingston Petersen (NNDKP) assisted Magyar Posta Takarék Real Estate Investment Fund (MPTIA), a public fund managed by Gránit Asset Management, with the acquisition of Equilibrium 2 office building in Bucharest from Skanska. With this latest acquisition, Gránit Asset Management now owns the Equilibrium office complex in its entirety, following the successful acquisition of the Equilibrium 1 building last year, also with legal assistance from NNDKP. Completed in late 2022, Equilibrium 2 provides roughly 20,000 square meters of premium leasable office space across 11 floors. The building holds multiple best-in-class certifications, including LEED Platinum, Access4You Silver, WiredScore Platinum, standing out for its commitment to sustainability, inclusivity and digital connectivity. Through this new transaction, Gránit Asset Management continues to expand its international portfolio, further strengthening its presence in Central and Eastern Europe. Partner Lavinia Ioniță Rasmussen, Real Estate practice, coordinated the legal team advising on the transaction. She was supported by Associate Bianca Isache from the Real Estate practice, while Partner Vlad Tănase, from the same practice, has overseen the leasing aspects related to the transaction. “We are happy to have had the opportunity to assist once again Gránit Asset Management with a significant acquisition in the Romanian real estate market, a move that secures their full ownership of the Equilibrium office complex. This transaction reflects their commitment to pursuing high-standard investments and developing a robust portfolio of premium-quality office buildings. We truly value the trust and confidence shown in our team and look forward to our continued partnership”, declared Lavinia Ioniță Rasmussen, Partner. NNDKP’s real estate team consistently advises major players in the market on some of the largest and most complex deals across asset classes, having contributed to the evolution of the real estate sector in Romania. With a strong portfolio of successfully closed transactions, the team is recognized as one of the leaders in the market and an advisor of choice for high-calibre clients. With more than 35 years of experience in the market, NNDKP lawyers provide integrated and specialised assistance in all areas of law involved in transactions and regulatory projects, helping to identify bespoke solutions and strategies for each client. *** About NNDKP Nestor Nestor Diculescu Kingston Petersen (“NNDKP”) is a promoter of business law in Romania, being independently acknowledged as a pioneer of the Romanian legal market. NNDKP offers full service and integrated legal and tax advice to companies from diverse industry sectors. Over the past 35 years, NNDKP lawyers have assisted and represented clients in milestone transactions and projects that have shaped the evolution of the Romanian business community. NNDKP represents Romania in prominent international professional alliances - Lex Mundi, World Services Group, International Attorneys Club - and is a founding member of SEE Legal and Three Seas Legal Alliance. The firm is constantly top ranked in all practice areas by the renowned international guides Chambers & Partners, Legal 500 and IFLR 1000. In 2025 NNDKP became a 7-time winner of the prestigious “Romania Law Firm of the Year” award at the Chambers Europe Awards gala and was named “Romania Firm of the Year” by Benchmark Litigation and “Romania Patent Firm of the Year” by Managing IP. *** For more information, please contact: Valentina Marin Marketing & Communications Director [email protected] +40 748 181 660 Laura Agatinei Marketing & Business Development Executive [email protected] +40 727 870 104 You can also visit us at:  www.nndkp.ro | Linkedin