Tax in Romania
Tuca Zbârcea & Asociatii provides a comprehensive direct and indirect tax advisory service to its clients, as well as strong support in major audits and any related litigation proceedings. The team, which is jointly led by Razvan Gheorghiu-Testa and Alexandru Cristea, has a strong handle on cross-border tax issues, which is key for the firm's large international client base. The firm, which launched a formal cooperation agreement with Andersen Global in 2019, also has a dedicated tax transfer pricing offering.
‘First of all, TZA’s team distinguishes itself through their professionalism. Our requests for assistance have always been addressed in a timely manner and most important, in an innovative way. Even in tough situations, TZA’s team has managed not only to identify multiple solutions but also to direct us in choosing the most appropriate one, on a case by case basis.’
‘Ioana Hrisafi, Alexandru Cristea, Narcisa Ichim and Cristian Velcu have always been available for us and provided their valuable insight and expertise. Most importantly, we have developed a close professional relationship and thus, our cooperation has so far been excellent. This could not have been possible without them acting not only as professional advisors but also like our colleagues, often identifying and promptly addressing our concerns as they appeared.’
Expur, part of Groupe Avril
Bet Active Concept S.R.L. / Fortuna
Asset Portfolio Servicing Romania (APS)
Societe Generale, Saint Gobain, Sanofi, Essilor, Capgemini, Sonepar, Renault, Ipsen, L’Oreal, Michelin, Arkema
- Advising a major drinks distributor on the tax implications of a new business model, which will see it enter into the alcoholic drinks distribution market.
- Assisting Carrefour with the implementation of a complex marketing and customer loyalty campaign, which has strong implications on the management of its VAT, corporate tax, and accounting provisions.
- Assisting oil seed processor Expur with a range of tax issues including an in-depth analysis of its local/EU excise and VAT-related framework.
Biris Goran SPARL has achieved huge success for its clients in major tax disputes with the authorities. Gabriel Biriş has considerable experience handling tax-related contentious matters and was previously Secretary of State in the Romanian Ministry of Finance in charge of tax legislation. Ruxandra Jianu is also noted on the advisory side, which is undertaken through the firm's consultancy arm, Biris Goran Consulting.
Banca Comercială Română
Electrica Muntenia Nord
One United Properties
- Succesfully representing cosmetics manufacturer Farmec in a major tax dispute with the Romanian authorities, which resulted in the annulment of a €15m tax decision.
- Acting for Banca Comercială Română in a tax dispute with the authorities relating to a major audit of its financial transactions in Romania.
- Succesfully defending energy distributor Electrica Muntenia Nord in a precedent-setting tax dispute that will have a big impact on the country’s energy sector.
D&B David si Baias SCA has an excellent reputation for tax litigation, particularly in areas such as VAT, transfer pricing, excise duty and environmental taxes. As part of the PwC network, the firm also offers strong advice to clients on the non-contentious side, and regularly supports the corporate team on M&A and restructurings. Highly rated litigator Dan Dascălu leads the team alongside corporate partner Ana-Maria Iordache and Anda Rojanschi.
‘The tax litigation team is one of the best in the field, being able to efficiently take care of the most complex matters with a high degree of technicality.’
‘Dan Dascălu is a reputable tax lawyer, a top choice when it comes to tax litigation, as he combines all the ingredients necessary for the success of the case – he is both an extremely experienced practitioner and a very knowledgeable theorist. The team he coordinates is formed of lawyers who also already leave their footprint in the the tax disputes they manage, such as Ana Maria Iordache and Mihail Boian.’
Grup Servicii Petroliere
Quadrant Amroq (part of Pepsi Group)
Prysmian Cabluri si Sisteme
- Advising CRH Ciment on the tax structuring for its acquisition of building materials manufacturer Pomponio.
- Advising Ovidiu Buluc and Isabelle Iacob as shareholders on the tax structuring of their sale of shares in Farmexim and Helpnet to Phoenix Pharmahandel.
- Representing real estate company, Central International CDG, in a €3.4m tax dispute with the tax authorities concerning additional VAT charges and related liabilities.
Nestor Nestor Diculescu Kingston Petersen's domestic and international clients benefit from an extremely deep bench of tax lawyers and consultants, including four partners. On the advisory side, the team provides strong transactional support and has recently been involved in several significant group restructurings. The contentious side is also busy, often acting for clients in tax and VAT audits and any related challenges in the courts. Alina Timofti and Marius Ionescu are major players in the market, and their team includes Lucian Barbu and Silviu Badescu.
- Advising a major meat producer on tax issues linked to the restructuring of its Romanian subsidiaries.
- Assisting a real estate company with the tax aspects of its group restructuring, which involved 37 subsidiaries.
- Advising a major logistics and courier company throughout a tax audit.
As part of EY Law, Radu si Asociatii SPRL has developed a very strong standing in the market for tax advice, particularly audit support and contentious matters. Emanuel Băncilă has an extremely strong reputation for tax litigation, and has successfully represented numerous multinationals in challenging multimillion-euro claims by the tax authorities. Non-contentious and advisory services are typically handled by the traditional EY side of the practice.
‘The firm has a very good understanding of the tax challenges for multinationals. The legal advice is precise and the team is highly responsive.’
‘The team was fully involved into the project, proving high qualification, understanding of our needs and excellent technical skills.’
‘The individuals in the team are very experienced, helpful, and provide quality information.’
‘Călin Stan has very good tax knowledge and is able to get to the core of tax matters quickly.’
Petrotel Lukoil, member of LUKOIL Group
ENKA Construction and Development BV, member of ENKA Inc.
Chep Equipment Pooling
Applied Physics Institute
Green Vision Seven, member of Hareon Group
- Represented Petrotel Lukoil in a high-profile tax evasion and money laundering dispute, which involved the successful suspension of a tax decision for €20m in additional excise duties.
- Assisting aviation company Romatsa with the successful annulment of €23m worth of tax claims following an audit by the National Agency for Fiscal Administration.
- Successfully representing two Bunge group companies in their challenge against an audit that resulted in €19m in additional liabilities
CMS is a very strong choice for regional and cross-border tax structuring advice, thanks in part to its extensive network of offices throughout Central and Eastern Europe. The team recently provided strong tax support to several major transactions in the media and retail space. The group is also known for its expertise in VAT audits, transfer pricing and litigation. Roxana Popel leads the team.
- Assisting Liberty Global and its Romanian subsidiary, UPC, with local taxation issues linked to the €18.4bn sale of its European assets to Vodafone.
- Assisting Polish retailer CCC with the tax structuring required for its €33m acquisition of its franchised Romanian business, including a network of 56 shops.
- Advising Accor Hotels on the tax aspects of its €11.35m acquisition of the Hotel Mercure Unirii in Bucharest.
DLA Piper Dinu SCA fields a versatile tax practice that works closely with other teams throughout the firm. Practice head Tudor Nedelea has strong experience acting for clients from a range of heavily regulated sectors, including pharmaceutical, energy, food and beverages, and gambling. The firm's international network makes it a popular choice for cross-border taxation issues. Tax litigation also features high on the agenda, with lawyers also advising on related white-collar criminal law issues. Tax director Ionela Florescu is also noted.
‘They are very committed to providing the best support.’
WIPRO Technologies SRL
OLX Services SRL
Early Game Advisors SRL/ Early Game Partners
- Advised Wipro Technologies on a tax audit covering the company’s income tax and VAT position over the last five years.
- Advising Prada on how to adapt its transfer pricing model for its local subsidiary to remain compliant with Romanian legislation.
- Acting for Stericycle Romania throughout an unannounced tax audit by the authorities.
Musat & Asociatii acts for a broad range of international and domestic clients. The team provides strong tax support and advice on company acquisitions and restructurings and, in recent work, has acted on several high-value matters. The firm's litigators are also extremely well versed in challenging decisions made by the tax authorities. Razvan Graure is the primary contact for advisory matters, while fellow co-head Angela Porumb handles the litigation side.
Brookfield Business Partners
- Advising Amazon on the expansion of its Romanian presence and tax incentives for local employees.
- Representing Nokia in a €11.5m dispute with the tax authorities over its decision to impose additional customs charges following an audit.
- Advising Sony on all local tax issues linked to the restructuring of its European operations.
Popovici Nitu Stoica & Asociatii's highly rated tax practice has been extremely busy providing transactional support across a range of deal types, including M&A, real estate acquisitions and intra-group restructurings. The team also works closely with other key departments, including litigation, IT, employment and white-collar criminal law and regularly assists clients with major tax audits. Mihaela Pohaci is one of the country's leading tax lawyers.
Auchan & Leroy Merlin
Impuls Leasing (a company owned by Raiffeisen Bank)
- Advising Dedeman on the tax aspects of its €120m acquisition of The Office, a 60,000sqm office project in Cluj-Napoca.
- Acting for RTC Proffice Experience on the tax aspects of its acquisition of the cleaning and hygiene products distribution business, Paper Plus.
- Advising DB Schenker, the logistics division of the German rail operator Deutsche Bahn, on the tax structuring for the merger of two of its Romanian Subsidiaries into DB Schenker GBS Bucharest.
Reff & Associates SCA provides the full spectrum of tax advice, with most of the non-contentious matters being covered through Deloitte. When it comes to tax litigation, the firm is extremely well regarded by clients and peers alike, with partner and litigation head Andreea Artenie a key name in the market. Cristi Secrieru is also noted.
‘Very good knowledge on taxes and understanding of the tax system.’
‘Cristi Secrieru and Andreea Artenie are experienced with dealing with taxes from a legal perspective and have a good understanding of tax issues.’
Schoenherr si Asociatii SCA provides specialist tax advice through a standalone team led by Theodor Artenie. The group works closely with the firm's administrative litigators in numerous high-value tax disputes. The practice is also noted for transfer pricing issues, where it regularly assists its multinational clients, as well as for VAT and transaction-related tax structuring.
‘Schoenherr is an international firm, yet they manage to be quite flexible when it comes to ensuring partner-contact and providing tailored solutions. A particularly unique feature in the Romanian market is that they have an all-inclusive approach, with real estate and general legal advice being delivered together with tax advisory.’
‘They are a good option in the market for high-quality integrated legal and tax advice of an international level. I enjoyed working with them, they are responsive and provide high quality advice. Would definitely recommend Theodor Artenie and his team for tax advice.’
‘Theodor Artenie is a very capable and very practical tax advisor. He is very aware of our realities and understands our business and this is visible in how applied his advice is.’
- Acting for Alpiq Energy on a €175m tax dispute with the Romanian authorities, which included the successful stay of an enforcement decision.
Bohalteanu şi Asociaţii
Bohalteanu şi Asociaţii has an experienced team led by Ionut Bohalteanu. The practice is particularly notable for its expertise in areas such as tax fraud, compliance and cross-border issues. The firm acts for clients across a range of sectors, including technology, retail and life sciences.
‘Excellent professionals, always available and never too busy to provide high quality advice in a prompt manner. Always providing clear and reliable advice.’
‘The team was very responsive and they delivered a profound legal opinion on short notice.’
‘Ionut Bohalteanu was very keen to understand the client’s needs and to provide oriented tax advice from both business and practical perspective.’
Cerha Hempel Spiegelfeld Hlawati
India Law Offices LLP
- Advised data analysis company Cognetik on indirect and cross-border tax issues.
- Assisted Slovenian pharmaceutical company KRKA with the tax regime applicable to speaker and consultancy activities carried out by healthcare professionals.
- Advised Cerha Hempel Rechtsanwälte on the tax implications of the implementation of an employee participation programme in Romania.
bpv Grigorescu Stefanica is a good choice for tax structuring advice and acts for various domestic and international clients on related issues, including transactional and day-to-day support and litigation. Practice head Anca Grigorescu has over 20 years experience in the market, and Alexandru Rusu is also very active on the corporate support side.
Real Garant Versicherung AG
VTG Rail Logistics
- Advised building materials supplier, Wienerberger, on tax issues linked to the company’s reorganisation within Romania, including the integration of two of its subsidiaries.
- Advising insurer, Real Garant Versicherung, on a variety of issues including the tax treatment of its insurance contracts.
- Acted for VTG Rail Logistics on the tax issues linked to the establishment of its business in Romania, including the incorporation of its branch office and its VAT registration.
Adrian Tomescu leads the team at Buzescu Ca, which is highly experienced in advising clients on domestic and cross-border taxation issues. Recently, the firm has been involved in several tax audits linked to the electricity trading sector.
‘They go above and beyond the call of duty to provide us with invaluable advice which greatly aids and assists us in the running of our business in Romania.’
Central European Drilling
- Acting for EDF Trading on a Romanian tax audit concerning electricity trading carried out by the company’s Romanian branch.
- Advised Statkraft Markets on a tax audit relating to cross-border electricity trading operations carried out from Romania.
- Assisting US manufacturer Kautex Textron with the taxation of the dividends distributed by a Romanian subsidiary to the foreign shareholders.
For companies based in the second city of Cluj, particularly start-ups and those working in the IT sector, Laurentiu, Laurentiu & Asociatii is a very popular choice. Alin Mihai Laurentiu leads the team, and has good experience advising on the tax implications of employee incentive schemes. Achim-Sorin Razoare is also recommended.
‘Their strengths are the knowledge and experience they demonstrate when addressing different topics, managing to provide fast comprehensive responses in a timely manner.’
‘The firm stands out as having expertise in IT taxation and related topics.’
Italian Cable Company
Tora Trading Services
- Advising clients such as Telenav Software, Steelcase, Polus Real Estate on the tax implications of employee benefit schemes.
- Advising Italian Cable Company on the tax structuring of a stock options plan.
- Assisting Telenav Software with the tax implications related to the secondment of several of its employees to a Chinese subsidiary of Telenav.
MPR Partners | Maravela, Popescu & Roman has core expertise handling international tax structures on major transactions, as well as providing strong day-to-day compliance and litigation advice. Practice head Felix Tapai is a certified tax consultant with over 15 years experience in the market, and founding partner Gelu Maravela is also recommended by clients.
‘A very professional team. Always close to the client and easy to reach. Flexible, hardworking and prompt in answers and opinions.’
‘Excellent expertise, competent, reliable, fast and friendly.’
‘Since meeting Gelu Maravela, I am sure that for every problem I have the perfect solution.’
Alpha Parking (Interparking)
Precision Medicine Group
- Advising chemicals manufacture Chimcomplex on all the tax issues linked to its €127m acquisition of several business assets from Oltchim as part of its privatisation.
- Acted for pharmaceutical and healthcare group Precision for Medicine on the tax structuring of its acquisition of Argint International.
- Assisted construction company Arinvest Holding with various tax matters linked to VAT registration and the acquisition of real estate assets.
Popescu & Asociatii has a very strong reputation for contentious tax advice, thanks in part to the standing and experience of Octavian Popescu. The firm also offers non-contentious tax advice on issues such as direct and indirect tax, transfer pricing and VAT.
‘They are very keen to obtain a result. They succeed to combine many areas of practice in order to integrate the solution for the tax issue. Frankly I do not know what other teams in the market are so integrated and successful in combining experience from multiple areas of law in order to deliver real tax advice.’
‘Octavian Popescu is the key figure, being one of the most reputed litigators in Romania. He is a lawyer who delivers results and succeeds to take out whatever argument you may have and makes it invincible.’
Teamnet International SA
Mega Image/Ahold Delhaize Group
- Successfully representing Alka Co, a leading producer of dry fruit snacks, in a €10m dispute over import duties on pumpkin seeds.
- Representing Electrica Furnizare in several tax disputes with the authorities concerning inter-company agreements between the company and its major shareholder.
- Advising Teamnet International, throughout its insolvency process, on the restructuring of its outstanding debts to the tax authorities.