What tax advisory means here
Compliance answers the question how do I report this. Advisory answers the question what is this, in Romanian tax terms, and what does it cost. The second question is the one that decides the first.
Most of what reaches us falls into a small number of shapes. A group is deciding where to book a transaction. A foreign company is about to sign a contract and does not know whether Romanian VAT applies. A founder is choosing between the micro regime and corporate tax. A shareholder wants to take money out and needs to know what is withheld. A tax inspection has raised a point and the company needs a defensible position, not an opinion.
We work the way a tax question actually has to be worked: find the law in force on the relevant date, read it against the case law and administrative practice, stress-test the reading against the argument ANAF would make, and then say what we think and how confident we are. Where the answer is genuinely uncertain, we say that too, and quantify the exposure rather than hiding it in a hedge.
Corporate income tax and the micro-enterprise regime
Romanian corporate income tax is charged at 16% on the taxable profit — the accounting result adjusted for non-deductible expenses, non-taxable income and fiscal deductions. Around that headline sit the rules that actually determine the bill: deductibility limits, interest limitation, fiscal depreciation, provisions, loss carry-forward, and reliefs such as the deduction for research and development and the exemption for reinvested profit.
Alongside it runs the micro-enterprise regime: a turnover tax of 1% from 2026, available up to EUR 100,000 of revenue, conditional on the company having at least one employee, with excluded activities and shareholding conditions attached. It is the most frequently misapplied regime in Romanian tax law, because companies enter it at incorporation and then stop monitoring the conditions. Crossing the ceiling mid-year, losing the employee, or restructuring the shareholding all move a company back to corporate tax — sometimes retrospectively within the year. The comparison, with the arithmetic, is in the guide on the micro-enterprise regime versus corporate tax.
What we do here: model both regimes on your actual numbers, monitor the conditions period by period rather than annually, and tell you before a threshold is crossed rather than after.
VAT: the questions that come before the returns
VAT advisory is separate from VAT compliance. Compliance takes a transaction whose treatment is settled and reports it. Advisory decides the treatment.
The recurring questions: where is the place of supply for a service invoiced from or to Romania; does a chain of supplies of goods produce a Romanian registration obligation; does storing goods in a Romanian warehouse create a fixed establishment for VAT; when does the domestic reverse charge apply; what evidence actually supports zero-rating an intra-Community supply; how do marketplace and platform rules allocate the supply.
Since 1 August 2025 the standard rate is 21% and the reduced rate 11%. That change did more than move a number: it altered the rate applicable to categories of goods and services that had been stable for years, and contracts with fixed gross prices absorbed the difference. Where a treatment is uncertain, we set out the position in writing before the invoicing pattern is fixed, because a VAT error repeats every month until it is found.
Dividends and distributions
From 2026 the dividend tax is 16%, withheld at source when the dividend is paid. Three layers sit under that sentence and each of them changes the outcome.
The accounting layer. Only distributable profit can be distributed, determined from statements prepared under the Romanian regulations. Interim distributions during the year are possible under conditions, with a regularisation at year end.
The treaty layer. For a non-resident shareholder, a double tax treaty may reduce the Romanian rate — but only if a valid tax residency certificate is presented in time. Presented late, the domestic rate applies and recovery is a procedure rather than a formality.
The EU layer. The parent-subsidiary regime can exempt distributions to a qualifying EU parent where the holding percentage and holding period conditions are met.
Alternatives to a dividend — salary, director’s remuneration, interest on a shareholder loan, a management fee — each carry a different combination of income tax, contributions, deductibility and transfer pricing exposure. We model them together rather than in isolation. The detail is in the guide to dividend tax in Romania.
Non-residents, withholding tax and treaties
Payments from Romania to non-residents — dividends, interest, royalties, commissions, certain services, management fees — can attract Romanian withholding tax, and Romania has an extensive treaty network that modifies the domestic rates. The practical work is rarely the rate itself. It is establishing what the payment actually is for treaty purposes, obtaining the residency certificate before payment rather than after, documenting beneficial ownership, and reporting the payments correctly in the annual informative return.
We describe the regime as it is, factually. We do not advise on arranging tax residence or on structuring to avoid a Romanian taxable presence. The full treatment is on the page about withholding tax on non-resident income.
Written opinions
Where the answer needs to survive being read by someone else — an auditor, a board, a counterparty, a tax inspector two years later — it goes in writing. A written opinion sets out the facts as you described them, the legal framework with the exact articles relied on, the interpretation, the counter-argument ANAF would put, the relevant case law and administrative practice, and a conclusion with the residual risk stated plainly.
That last element is the one that distinguishes a usable opinion from a comfortable one. A position with a 20% chance of challenge is worth taking with eyes open; the same position taken without knowing that is a liability. How we handle individual queries, provisions that can be read two ways and new amendments to the Tax Code, and when an advance tax ruling is worth requesting: tax opinions and queries.
Support during a tax inspection
Advice is most valuable before the transaction and least valuable after the assessment — but companies do not always call at the ideal moment. Where an inspection is already open, we take over the technical dialogue: the response to the requests for information, the argument on the points raised, the observations on the draft report, and, where the assessment does not hold, the appeal. That work is described on the page about ANAF tax inspections and appeals.
Who you are talking to
A small team, and you speak to the person who answers your question.
Our tax consultants — licensed by the Romanian Chamber of Tax Consultants (CCF), members of CECCAR and ACCA, with more than 20 years of practice in Romanian and cross-border taxation. They write the opinions and lead the inspection work.
Silvia — chartered accountant, member of CECCAR, with over 17 years in Romanian accounting and reporting. She leads the accounting and year-end side, where most advisory questions originate.
Communication is in English, Italian or Romanian. There is no account manager between you and the person who answers the question, and there is no ticket queue.
