International Tax

International tax is approaching a moment of once-in-a-generation change, as proposals for more coordinated global corporate taxation come closer to reality. Our worldwide presence allows us to give strategic advice on such long-term issues, as well as help clients navigate today’s complex tax rulebooks. 

The globalisation process characterised by growing international trade has brought higher complexity of taxation issues posed to both multinational enterprises and tax administrations.

Our approach 

Companies that operate across borders or have a presence in multiple jurisdictions know that complying with local tax laws, and meeting reporting requirements is a resource-intensive task. It demands local market expertise from trained professionals. 

Our global network is ideally suited to serve large multinationals and global-minded mid-sized companies who need on the ground expertise in multiple jurisdictions. We also have substantial expertise helping fast growing companies who need a tax efficient structure for their first international expansion. The network means we have a clear view not only of the global trend, but an on-the-ground view of disruptive, single country initiatives such as national taxes on digital services. 

We have a particular focus on corporate structures. Whether it is the effects of Brexit or changes triggered by the OECD Base Erosion and Profit Shifting (BEPS) action plan, the risk of tax nexus is a growing and constant concern for businesses. Navigating such an ever-evolving business environment increasingly requires an integrated, global approach with access to coordinated advice that can support your long-term strategy and business decisions. 

Our services 

• Full-service international corporate tax advice including: 
  • Corporate structuring; 
  • Corporate transactions including M&A; 
  • Global tax credits and incentives. 
• Guidance on the tax implications of worldwide mobility and employment. 
• VAT and indirect taxes. 
• Transfer Pricing. 
• Risk analysis on global initiatives such as the OECD’s BEPS. 
• Compliance assistance including help building strong internal teams. 
• Global mobility of employees. 
• Specialist advice for privately-owned businesses, business owners, and high net worth individuals that are operating internationally

 Local and cross-border tax structuring

Our integrated network of tax specialists is highly experienced in addressing complex taxation aspects and providing tax structuring options in an optimised manner, from design to implementation.

Our team of experts can advise you on:

• international tax aspects of business restructuring;
• identifying solutions for intellectual property migration to address operational changes in your business structure;
• suggesting optimal finance and treasury solutions for your business;
• mitigating any local tax risks;
• provide you advice with respect to the tax/legal form in which an entity can be established in Romania;
• provide full legal advice on incorporation issues, in cooperation with our trusted external lawyers with whom Forvis Mazars cooperates.

 EU tax legislation

Our tax specialists are experienced in advising clients on various issues deriving from the EU tax legislation, such as:

• EU tax opportunities for our clients;
• Compliance with relevant provisions of EU tax law;
• Assistance on legal actions against local tax authorities and litigation before local courts.

Withholding tax

Non-residents obtaining revenues from Romania (e.g. interest, royalties, services, dividends, commissions etc.) are subject to a 16% withholding tax (“WHT”) in Romania.

Our tax experts can advise you on the applications of the more favourable conditions provided either by the relevant EU Directives transposed into Romanian legislation, or the relevant Double Taxation Treaties concluded by Romania with partner countries.

Moreover, we can assist you with:

• finding solutions for reimbursement of the excess WHT paid in Romania, as well as with the preparation and filling of the required compliance;
• obtaining the certificate for proof of payment of the WHT in Romania, based on which the non-resident may claim tax credit/tax exemption in its country of residence.

Permanent establishment / VAT fixed establishment

A permanent establishment is a special tax concept that designates, in principle, the taxable presence of a non-resident company in a foreign country.

Our tax team is able to help you with:

• performing an in-depth assessment on whether a permanent establishment is triggered in Romania, as well as analysis in respect of a VAT fixed establishment;
• recommendations with respect to changing the business structure to mitigate such risks;
• the registration process of both a permanent establishment, and/or a VAT fixed establishment, as well as with all the required past and future tax compliance.

Our tools and solutions 

Our international tax network creates a wide range of innovative and bespoke tools and solutions to support our tax clients. These include online resources such as the COVID-19 Global Tax and Law Tracker, and our portfolio of DAC6 services.  

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