Comprehensive Tax Advisory Services

We understand that tax implications can significantly impact your business decisions, and we are committed to providing tailored solutions that mitigate risks and maximize opportunities.

Our team of experienced tax lawyers possesses in-depth knowledge of Romanian tax legislation and international tax principles, enabling us to provide strategic advice that aligns with your business objectives.

Our Tax Law Expertise

Our comprehensive tax services cover all aspects of Romanian and international tax law:

Corporate Income Tax

We advise on all aspects of corporate income tax, including tax planning, restructuring, and compliance. We help businesses optimize their tax burden while ensuring adherence to Romanian tax regulations.

Corporate Income Tax Services

• Tax Planning: Strategic planning to minimize tax liability while maintaining compliance
• Tax Optimization: Structuring business operations for maximum tax efficiency
• Tax Compliance: Preparation and timely filing of corporate tax returns
• Tax Audits: Representation and assistance during tax authority audits
• Tax Appeals: Challenging unfavorable tax assessments before authorities and courts
• Entity Restructuring: Tax-efficient merger, acquisition, and reorganization strategies

Corporate Tax Rates and Incentives

• Standard corporate income tax rate and special rates for certain sectors
• Microenterprise flat tax regime
• Small business tax incentives and deductions
• Research and development tax credits
• Beneficial tax treatment for specific industries
• Loss carryforward and carryback provisions

Value Added Tax (VAT)

We provide comprehensive VAT services, including registration, compliance, and advisory on complex transactions. Our expertise covers both domestic and cross-border VAT issues, ensuring seamless operations within the European Union.

VAT Registration and Compliance

• VAT registration procedures and requirements
• Voluntary registration for businesses below thresholds
• Monthly and quarterly VAT return preparation and filing
• VAT deduction and recovery procedures
• Input VAT management and optimization
• VAT audit representation and defense

Cross-Border VAT Issues

• Intra-EU supply of goods and services VAT treatment
• Reverse charge mechanism compliance
• Imports and exports VAT procedures
• Distance sales VAT registration requirements
• Digital services VAT in the EU
• VAT on international transactions and transfers

Complex VAT Transactions

• VAT treatment of specific industries (construction, financial services, etc.)
• VAT in real estate transactions
• VAT on supply of goods and services
• Reverse charge and self-billing procedures
• Simplified procedures and special schemes
• EU VAT compliance for e-commerce businesses

Personal Income Tax

We offer expert advice on personal income tax matters, including taxation of employment income, investment income, and other sources of income. We assist individuals and expatriates in understanding their tax obligations and ensuring compliance.

Personal Income Tax Services

• Employment income taxation and withholding obligations
• Investment income taxation (dividends, interest, capital gains)
• Self-employment and business income taxation
• Rental income taxation
• Tax-advantaged investment structures
• Personal tax planning and optimization

Expatriate Taxation

• Foreign employee tax residency status determination
• Tax treaty benefits and foreign tax credits
• Immigration and tax registration requirements
• Expatriate tax compliance and reporting
• Relocation and expatriate cost-of-living allowances
• Tax-efficient compensation structuring

Tax Deductions and Credits

• Personal income tax deductions and allowances
• Tax credits for dependents and family support
• Healthcare and insurance deductions
• Education and training expense deductions
• Charitable donation deductions
• Tax relief for low-income individuals

Transfer Pricing

We assist multinational companies in establishing and documenting transfer pricing policies that comply with Romanian and international standards. We help clients mitigate transfer pricing risks and ensure compliance with arm’s length principles.

Transfer Pricing Services

• Transfer Pricing Policy Development: Design of arm’s length pricing methodologies
• Documentation Compliance: Preparation of required transfer pricing documentation
• Benchmarking Analysis: Economic comparability studies and pricing analysis
• Transfer Pricing Audit: Defense against transfer pricing adjustments
• Advance Pricing Agreements (APA): Negotiation with tax authorities for pricing certainty
• Transfer Pricing Disputes: Representation in tax disputes over transfer prices

Intercompany Transactions

• Intercompany service pricing and cost allocations
• Financing and loan pricing between related parties
• Royalty rates for intellectual property
• Cost sharing arrangements
• Supply chain and distribution pricing
• Shared service center pricing models

Tax Due Diligence

We conduct thorough tax due diligence investigations for mergers, acquisitions, and other corporate transactions. This service helps clients identify potential tax liabilities and risks, enabling informed decision-making.

Due Diligence Scope

• Historical tax compliance and filing review
• Tax audit history and pending disputes
• Transfer pricing documentation assessment
• Tax provision and contingency analysis
• Environmental and employment tax liability assessment
• Deferred tax asset and liability evaluation

Transaction Tax Analysis

• Tax implications of proposed transaction structure
• Step acquisition and reorganization tax treatment
• Tax liabilities and post-closing adjustments
• Indemnification and escrow considerations
• Tax risk allocation between parties
• Transaction tax optimization strategies

Tax Litigation and Dispute Resolution

We represent clients in tax audits, appeals, and litigation before Romanian tax authorities and courts. We provide strategic advice and robust representation to protect your interests.

Tax Authority Proceedings

• Tax audit representation and management
• Information requests and document submission
• Tax assessment objections and appeals
• Administrative complaint procedures
• Settlement negotiations with tax authorities
• Mutual agreement procedures (MAP) with foreign authorities

Tax Court Litigation

• Tax court claims and appeals preparation
• Litigation strategy and case management
• Expert witness coordination and testimony
• Appeal procedures before higher courts
• Representation in substantive tax trials
• Settlement negotiations in pending disputes

Additional Tax Services

Excise Duties and Local Taxes

• Excise duty compliance for specific goods
• Building taxes and property tax optimization
• Land taxes and registration requirements
• Local fees and environmental charges
• Customs and import duty procedures
• Tax incentives and exemptions

Tax Compliance and Reporting

• Tax return preparation and filing (corporate, personal, VAT)
• Tax payment and management
• Documentation retention and archiving
• Regulatory reporting and information returns
• Transfer pricing documentation maintenance
• Tax accounting and record keeping

Advanced Tax Services

• Advance Tax Rulings: Obtaining certainty on tax treatment of transactions
• Tax Training: Customized tax training for management and staff
• Tax Optimization: Restructuring advice to minimize tax burden
• International Tax Planning: Cross-border structuring and treaties
• Tax Restructuring: Merger, acquisition, and reorganization tax planning
• Tax Software and Systems: Tax compliance technology implementation

International Tax Law

We provide consultancy regarding international tax treaties and cross-border transactions, helping clients avoid double taxation and optimize their global tax position.

Tax Treaties and Benefits

• Tax treaty eligibility and benefits assessment
• Foreign tax credit and deduction procedures
• Treaty interpretation and application
• Certificate of tax residency assistance
• Relief at source procedures
• Mutual agreement procedure (MAP) for treaty disputes

Cross-Border Transactions

• Inbound investment taxation structuring
• Outbound investment and permanent establishment risks
• Dividend repatriation and withholding tax minimization
• Branch vs. subsidiary structure optimization
• Transfer pricing for cross-border transactions
• Base erosion and profit shifting (BEPS) compliance

Double Taxation Avoidance

• Double taxation identification and elimination
• Foreign tax credit optimization
• Treaty relief procedures
• Allocation of income between jurisdictions
• Tax residency determination
• Permanent establishment analysis

Why Choose Atrium for Tax Services?