Advised Mondial on a tax dispute with Romanian authorities, resulting in a definitive court decision obliging the tax authorities to initiate a Mutual Agreement Procedure with eight European jurisdictions. The High Court of Cassation and Justice has examined the possibility for courts to intervene in tax authorities' decisions on MAP procedures, taking into account the limits imposed by the principle of separation of powers and the principle of fiscal autonomy.

Successfully represented RAGT GROUP, one of the most important multinational groups activating in the Agriculture & FMGC industry, obtaining a landmark decision on the taxation of income obtained in Romania in the form of royalties paid for exclusive distribution rights.

Assisting and representing the Romanian subsidiary of the EDP Renewables group, one of the most prominent renewable energy producers in Europe, in several disputes pertaining to special income taxes levied by the Romanian legislator. Moreover, they are assisting the client in challenging the fiscal deeds issued by the Romanian Tax authorities in the 2015 – 2019 period, levying “building tax” on the supporting towers of wind turbines and solar panels, as well as matters referring to the enforcement of fiscal deeds. Representing SIF 1 IMGB in a court case seeking to annul fiscal decisions by the Romanian tax authorities that imposed additional VAT, CIT, and social contributions. The authorities artificially raised the prices of heavy machinery sold below production cost, leading to these additional taxes. The team secured favorable rulings from the Bucharest Court of Appeal, canceling the VAT liabilities, though the decisions are not final. The case involves complex tax issues related to corporation tax, VAT, and transfer
pricing.

Represents XPO in three annulment and four suspension claims before Romanian courts, challenging fiscal decisions related to transfer pricing adjustments, CIT and VAT liabilities, and VAT issues for intra-Community services and exports. The firm successfully dismissed significant tax liabilities and secured a re-check solution for others. Additionally, the team assisted XPO in challenging unlawful enforcement actions by the tax authorities and filed a claim to resolve XPO's fiscal situation, impacting the company's ability to obtain VAT reimbursements due to its high-risk fiscal classification following a prior tax audit.

Specialist lawyers: Andreea Artenie, Cristi Secrieru, Adelina Raportaru, Vlad Grosu.

Assisting Banca Comerciala Romana (BCR), a member of Erste Group, the most important financial group and the largest bank in Romania, in the largest tax dispute pending on the Romanian market. BCR was subject to one of the very first and largest tax audits envisaging financial transactions in Romania.

Acting as tax consultant for successful retailer Lidl, for all their day-to-day activities, covering all tax matters, from profit tax, VAT, excise duties, customs taxes, social security contributions, transfer pricing matters, as well as compliance and European matters. 

Assistance for Hagag Development Europe with the review of tax and accounting implications related to the group’s real estate properties in Romania.

Assisting a major global FMCG producer, in two major tax disputes following the company being subject to two large tax audits on transfer pricing matters.

Successfully represented Stratum Energy, the Romanian division of an energy company incorporated in the United States and active in the exploration and extraction of petroleum in Romania, with the annulment of an EUR multi-million tax liability. 

Specialist lawyers: Gabriel Biris, Ruxandra Jianu, Sorin Biban, Ioana Cartite, Luciana Rainov, Alin Lazar, Paul Chichernea, Anda Diaconescu, Filip Cucu.

Advising foreign investor on tax structure to purchase land in Romania.

Considering Romanian VAT issue in respect of loan and interest payments to foreign company.

Representing client in respect of claim for customs duties in respect of import of food stuffs into Romania.

Advising on repatriation of profits to client via a neutral tax country.

Considering with client and tax accounts transfer pricing of services between Romanian client company and parent holding company.

Advising Dacian Petroleum, a company acting in the petroleum services field, with respect to preparing and revising a set of contracts used in the day-to-day activity, such as fluid transport agreement, mechanic and electric maintenance agreement, pump repair works agreement, construction work agreement, including from a tax perspective (VAT, permanent establishment, resident/non-resident tax treatment etc.).

Advising a Romanian financial institution part of an international reputed group, in connection to tax implications of an envisaged transfer of shares from the actual shareholder to an affiliate, most particularly on transfer pricing aspects.

Advising Genesis Biopharma, a life sciences company providing vaccines, human biologicals, and specialty pharmaceuticals, in connection to various claw - back contribution aspects, including the assessment of the clawback contribution computation method, as well as drafting a challenge of the relevant notification received from the National Health Insurance House with reference to the percentage related to claw-back contribution and the assessment of the procedure for appointing a tax representative for claw-back purposes etc.

Advising a global biotechnology company that invests in scientific innovation, with respect to various tax matters related to the sponsorship granted to health care personnel.

Specialist lawyers: Ionut Bohalteanu, Silvia Sandu.

Representation of Foreign and Romanian companies in fiscal related litigations before the fiscal authorities and in courts, such as VAT reimboursement, expenses deductibility and tax.

Legal assistance and representation services rendered in favour of a company that activates the real estate sector in the judicial administrative procedures regarding the annulment of a taxation decision by which the fiscal bodies established fiscal obligations of results from the application of the legal provisions regarding the VAT adjustment.

Legal assistance to a multinational active in the consumer products area for the reorganisation of its Romanian presence.

Legal assistance to a real estate developer for the reorganisation of its Romanian entities. 

The law firm is currently assisting and representing the Company in front of the courts of law in the process of seeking the annulment of a tax assessment decision imposing the client additional tax liabilities, namely VAT, late payment interest and penalties, amounting to approximately €15 million. The case complexity comes from the fact that the tax authorities requalified the transactions carried on separately by the company, i.e. supply of goods and services, in single VATable transaction, i.e. considering it a supply of goods with installation, as to be able to audit a period outside the statute of limitation and also to apply local Vat on such transaction. Thus, this case entails both tax procedural issues concerning the status of limitation concept as well as substantial tax arguments on the criteria to be met for requalifying a transaction into a supply of goods with installation, under the ECJ case-law.

Specialist lawyers:Sorin David, Dan Dascalu, Ana-Maria Iordache, Mihai Boian, Andrei Iancu, Anda Rojanschi, Cristina Paduraru, Romana Petre, Adina Oprea, Andreea Tortov.

Assistance for BRF in relation with the transfer of locally registered trademarks towards an affiliated entity in Turkey. The client is currently restructuring its activity in Romania and intends to transfer in another jurisdiction the trademarks that are registered locally. The firm has established an approach that would enable (i) sustaining the low impact of the trademarks on the Romanian business, while (ii) ensuring the compliance with the legal provisions regarding the price of a transaction between related parties and (iii) finding a proper methodology to sustain the reduced value of an intangible under OECD principles.

Assisting the client and litigation team with complex analysis of potential VAT implications in respect of turnkey projects undertaken by operational companies in Romania. This project required an analysis of a complex structure from financing and operational point of view, with various chain transactions between the parties involved. The law firm has also assisted the client in assessing potential implications (not only related to tax) with respect of assignment of receivables in Romania and impact in financing structure.

Reckitt Benckiser requested the firm's assistance in clarifying the excise duties and customs treatment of a certain product sold on the Romanian market further to Brexit. This project proved to be difficult and challenging due to specific manufacturing process of the respective product, not clearly specified by the European and Romanian legislation. In this context, the firm also assisted the client in submitting a confirmation letter with the authorities, the team has been involved in the discussions with the tax authorities, managing to obtain clarification on the topic.

Bellotto Holdings Limited acquired a Romanian entity manufacturing industrial blinds and shutters. The firm assisted the client during the transaction, but also in analysing potential scenarios for the supply chain process and the related implications from a VAT and customs perspective, upon the completion of the transaction. The firm has also analysed the potential scenarios from a pre and post Brexit perspective. The team advised the client on alternative business structures further to the acquisition of a Romanian business.

Stericycle Romania was subject to an unannounced tax audit that covered a 6-year open tax period - which is not in line with the procedure related to unannounced audits. Thus, the firm has actively assisted the client to manage the requests of the tax inspectors and provide the information requested in a manner that ensured compliance with the legislation and reduced the pressure on the client’s team involved in gathering such information. The team has also coordinated discussions with the tax authorities on implementing the proposed tax adjustments and preparing the corresponding documentation.

Specialist lawyer: Tudor Nedelea.

Advised DontPayFull, a Romanian affiliate marketing company, on the legal and tax framework for initiatives to enhance their online platform's engagement. The firm’s analysis included the legal qualification of proposed operations and their tax implications, covering VAT, corporate tax, and personal income tax. Collaborating closely with the client, they structured strategies that drive user adoption while minimizing legal and tax risks, supporting their growth objectives effectively.

Advised a major company in the scrap metal waste industry on structuring its operations and managing related VAT implications. The assistance involved analyzing complex cross-border transactions and ensuring tax efficiency and compliance.

Provided comprehensive day-to-day legal and tax advisory for AD Auto Total on VAT, corporate tax and personal income tax, ensuring seamless compliance for the client.

Conducted an in-depth VAT review for the client, the largest integrated steel producer in Romania. The firm’s analysis assessed compliance across complex transactions, identified potential VAT risks, and offered strategic recommendations to optimize VAT positioning. This proactive approach helped protect the client’s operations and ensure compliance with VAT regulations.

Assisted two international real estate developers with the VAT refund process in Romania. The services included reviewing their transactions, ensuring compliance with local VAT regulations, and optimizing the refund procedure. The firm’s team worked closely with both developers to navigate the complexities of the process, ensuring timely and accurate refunds while minimizing any potential tax risks.

Specialist lawyers: Luisiana Dobrinescu, Anamaria Chiru, Andrada Alexandra Ples, Filip Iana, Anca Nica.

Assisting EFA DYNAMIC TRADE FINANCE FUND, an international investment fund, in a lawsuit seeking the annulment of a tax decision of the fiscal body which had established an additional tax base of over €1 million. The case relates to the sale of immovable assets from an insolvent company to one of its affiliates.

Assisting Zentiva Group in two cases against the Fiscal Authorities requesting the annulment of tax decisions by which the client was obliged to pay certain amounts as corporate tax and VAT.

Assisting Delfingen RO Transilvania in several stay actions claims and annulment claims regarding the decisions of the tax authorities on additional corporate income tax and VAT. 

Specialist lawyers: George Trantea, Razvan Ionescu, Daniel Mazilu, Adrian Cristea, Alin Grapa, Adrian Zamfir, Eduard Morariu.

Successful representation of an agricultural equipment distributor in a dispute against the National Agency for Fiscal Administration (ANAF) for the annulment of control measures having imposed additional tax following the reassessment of the company's transfer pricing practices.

Specialist lawyer: Cristina Bojica.

Provide comprehensive tax advisory services to a STADA M&D regarding their daily business activities in Romania, addressing all tax areas, including profit tax, income tax, withholding tax, and VAT. Their team is also assisting the company with tax advice related to a state-aid funded investment in Turda. Their strategic guidance ensures the client remains compliant while maximizing potential tax benefits in their operations.

Provide day-to-day tax consultancy services to Accord Healthcare, offering guidance on various tax implications related to profit tax, withholding tax, VAT, and business structuring. The team ensures that clients navigate the complexities of tax regulations effectively, helping them optimize their tax positions while maintaining compliance with applicable laws. This ongoing support is tailored to meet the specific needs of their clients, enabling them to  make informed decisions that align with their business objectives.

Have assisted the client, a prominent manufacturer of agricultural machinery and equipment, in maintaining the suspension of enforcement for the fine issued by the Romanian Competition Council. Additionally, they have supported the client with various matters related to cross-border transactions, specifically involving the dispatch of employees from Romania to Ukraine for maintenance and repair services concerning specialized equipment. The team provided comprehensive legal guidance to ensure compliance with relevant regulations and facilitate the smooth execution of these crossborder operations.

The law firm has been appointed as an expert party in a court dispute involving their client, a major player in the pharmaceuticals sector, and the local tax authorities concerning specific profit tax and VAT issues. Their role includes providing specialized analysis and insights to support their client's position in this legal matter.

Provide tax advice related to transactions in Romania to a leading international defense and technology company, focusing on matters such as profit tax, VAT, personal income tax and social contributions. Their support ensures compliance with local tax regulations and optimizes the client's tax position in their business operations.

Specialist lawyers: Rusandra Sandu, Luiza Bedros, Theodor Artenie, Carmen Mazilu, Andrada Popescu, Cristina Stamboli.

Representing Continental Automotive Systems in a tax litigation in relation to fiscal obligations concerning corporate income tax for Research & Development activities as well as for intra-group charges for foreign personnel. The Romanian Tax Authorities rejected the supra-deductibility of the R&D activities conducted by the client, and this became a landmark case in the interpretation of the legal provisions regulating such matters. Alba Iulia Court of Appeal accepted the client’s claim and the firm has, consequently, created relevant jurisprudence in relation to the supra-deductibility of R&D activities, a solution confirmed by the High Court of Cassation and Justice in June 2024.

Specialist lawyers: Calin Dragoman, Cristian Radu, Marina Pacuraru.

Legal assistance and representation for a large distributor of construction and finishing materials in a fiscal inspection procedure whereby payment obligations in a significant amount were set. The relevant matters under discussion in the file refer to the legal conditions provided for VAT deduction and VAT exemption, considering the particular aspects of the disputed matter, and to the refusal of the national Tax Authorities to approve such deduction/ exemption. Furthermore, the Client was represented in the pre-litigious proceedings related to an authority’s refusal to reimburse fuel excise.

Legal advice for a Romanian electricity producer in relation to a fiscal dispute concerning a decision issued by the local authorities having as subject matter taxes arising from construction permits and the non-unitary interpretation of applicable legal provisions.

Legal assistance for a well-known Romanian player on the market of bottled mineral water related to the administrative proceedings required following the resolution of a VAT reimbursement related dispute. The role of the firm's department was to analyse the risks entailed by the content of the court decision (some of court’s orders being incomplete) as well as to carry on the correspondence with the competent Tax Authority in order to facilitate the reimbursement of amounts resulting from the annulment of administrative deeds.

Legal assistance and representation for a romanian subsidiary of a VPN services provider in a dispute related to the results of a tax inspection during which the Romanian Tax Authority expressed suspicions as regards the actuality of operations carried out by the company, thus additional VAT and income tax were calculated. Also, the inspectors submitted a criminal complaint for alleged tax evasion crime, consequently the company was not able to challenge the results of the inspection. The litigation aims to oblige the authorities to resolve the administrative challenge against the inspection results.

Specialist lawyer: Magda Dima.

Retained by Astra Holding, a German investment group (longstanding client) with regards to a real estate acquisition of an office park complex (three office buildings and retail space). They advise the client regarding the complex structuring of the transaction - reviewing and mark-up, binding offer, Romanian tax provisions related memos, including assistance (structuring memorandum, tax optimizations etc.) with regards to the project acquisition finance.

Advising Universal Music, the world’s leading music company, in connection with various fiscal and tax matters, including VAT compliance, the taxation system in respect of royalties, Intra-group transactions, loans and interests thereto, as well as representing the client in front of the tax authority, including assistance in tax/fiscal audits. They were required to dispense highly specialized tax and compliance advice tailored to the music industry. Assistance was provided to the parent company itself, as well as three companies from the same music production and distribution group.

Advising STB, the main overground municipal public transportation company located in Bucharest, on a range of tax and fiscal matters aimed at restructuring its debt of approx. €200 million. The team is providing assistance on a number of matters, including tax consultancy services relating to tax restructuring legislation, debt rescheduling, and advice on potential litigation related to the granted gratuities, among other matters, including transfer pricing.

Retained by Eberspaecher Controls Ro, an important R&D and engineering company, part of a major multinational group present in 28 countries, in order to provide assistance and representation before the tax authorities in relation to tax compliance and accounting services. Their assistance consists of complete support in tax services spectrum, including tax compliance services and relation to the designated tax authorities in various matters indicated by the client as well as accounting services and assistance with day-to-day matters. In addition, they provided assistance in relation with the setup of the transfer pricing policy applicable to the activities of their client.

Advising Enpower Energy, a prominent technical developer in the field of renewable energy on various taxation matters. They are assisting on a number of matters, including tax consultancy services relating to the energy projects carried out, assistance during tax audits and tax due diligence projects, as well as general tax advisory.

Specialist lawyers: Gelu Maravela, Felix Tapai.

Advising Amazon, one of the largest companies in the world, upon extending its local presence in Romania, with respect to various day-to-day activities, including a demerger process and the implementation of various systems implemented by local tax authorities.

Advising HAVI, one of the largest players in the logistic field in Romania, with respect to restructuring of the activities performed and changing the business model from distribution model to agent model.

Advising Ferring Pharmaceuticals, a multinational specialty biopharmaceutical group, on the tax legal aspects related to the company’s activities in Romania. They advised the client on issues such as taxation of the revenues paid by the company to  foreign speakers attending educational events and revision of the related agreements, as well as on the COVID-19 related tax incentives and government relief.

Advising Disney in connection with the local taxes imposed by Romanian National Center of Cinematography, by providing relevant legal steps to fulfil their local obligations. Also, the law firm assisted the client with submission of challenges related to the computation of the amounts due to the Romanian National Center as well as drafting clarification letters on the obligations imposed to the company. To this extent, they assisted the company also with the payment and declarative obligations towards the Romanian National Center.

Assisting Kaufland Romania in relation to a tax auditing process, including assistance with procedures during the audit, as well as subsequent tax challenge exercises. They have previously assisted this long-standing client with other tax matters, such as: restructuring of the retail business, compliance with various regulatory obligations, implementation of electronic cashiers, and tax aspects in relation to various supplier damages. Their work on this matter has involved assistance during the court challenges for the annulment of the additional tax obligations set by the tax inspectors, as well as performing tax due diligence regarding the acquisitions of real estate by the company.

Specialist lawyers: Iulian Popescu, Dan Minoiu, Razvan Graure, Monia Dobrescu, Angela Porumb, Roxana Bujoreanu, Alina Man, Adriana Popovici.

Assistance provided to a large bank active in Romania in a complex tax challenge, entailing complex profits tax and transfer pricing matters.

Assistance provided to a real estate developer in a complex tax restructuring process.

Assistance provided to a Spanish construction company in a complex tax litigation process.

Specialist lawyers: Alina Timofti, Marius Ionescu, Lucian Barbu, Silviu Badescu.

Tax advisory in connection to Stada M&D/Hemofarm´s daily business activity in Romania, as well as tax advice in relation to the integration of Walmark business in Stada, after the recent acquisition by Stada Group of Walmark.

Assistance for Walmark during tax audit and and day-to-day tax consultancy.

Tax advisory for Accord Healthcare, Kamtec Auto, Ferrostaal Oil & Gas, leading European retail chain, Zech Bukarest Construction and Intelligent Software Systems in connection to their daily business activity in Romania, as well as transfer pricing services.

Day-to-day tax consultancy for an international IT company.

Tax assistance for a leading European provider of transport-related services in the current tax audits/appeals/court actions with the tax authorities. The team assists the client in recovering VAT claims of €12 million from the Romanian tax authorities.

Specialist lawyers: Iulian Sorescu, Monica Colt, Carmen Mazilu, Miruna Ghinescu, Raluca Botea.

IBFD (International Bureau of Fiscal Documentation) invited the law firm to be the contributors for Romania for Corporate Taxation and Individual Taxation sections of the Country Guides, VAT TNS, DAC6.

Assisted Romanian Professional Tennis Player Simona Halep on all her tax matters.

Assisted Allianz Global Investors (comprises investment funds with investments in several countries, including Romania) in connection with a multiple-country project carried out based on European Court of Justice jurisprudence related to the discrimination of investment funds in order to identify cases where discrimination took place and, by way of consequence, identify related withholding tax recovery opportunities.

Assisted Azomures in various complex projects, such as: (i) assessment on the applicability of the VAT reduced rate for certain transactions; (ii) structuring of a commercial dispute and connected fiscal implications; and (iii) EU assignment of personnel and related tax implications.

Tax assistance for Impuls Leasing Romania IFN in connection with complex matters such as: (i) review of the applied procedures in connection to reclaimed vehicles to assess compliance with tax regulations; (ii) analysis and structuring of their supply chains for the acquisition of vehicles from various jurisdictions, for leasing/financing purposes, navigating various types of transactions: chain supplies under various Incoterms conditions, transactions subject to different assessments under the national legislations of the involved jurisdictions, incomplete deliveries and remedy mechanisms; (iii) new collaboration structures with various dealers in order to expand business; (iv) assistance regarding EU assignments of personnel, as well as connected income tax and social charges implications.

Specialist lawyers: Raluca Rusu, Ioana Nastase, Ileana Radu Cernat.

Assistance to Berlin Chemie A. Menarini, one of the largest pharmaceutical producers in Germany, in four proceedings before Romanian tax authorities, Romanian courts and ultimately the European Court of Justice in a project that will impact the VAT regime of cross-border pharmaceutical groups in the entire European Union.

Assistance to PPC Group (Retele Electrice Muntenia, Retele Electrice Banat, PPC Renewables Romania) and representation in several tax disputes seeking to challenge the tax decisions issued by the Romanian Tax Authorities to multiple entities within the group.

Assistance to Deutsche Leasing Romania IFN, part of Deutsche Leasing Group, one of the largest and strongest financial organisations in the world, in a cross-border dispute resolution arising from an additional withholding tax (WHT) imposed by the Romanian tax authorities in relation to the interest obtained by the financing entity from the financing granted to the Romanian company.

Assistance and representation to Leroy Merlin, a French-headquartered home improvement and gardening retailer, regarding the annulment of a tax assessment decision and in respect of the issuance of the adjustment decisions, as well as in highly complex tax litigation.

Assistance to Agroexpert/Izamar group, a leading company in the agribusiness, regarding the challenging of tax administrative deeds imposing additional tax liabilities consisting in ancillary obligations related to non-refundable amounts granted in the agricultural sector.

Specialist lawyers: Alex Slujitoru, Emanuel Bondalici, Bogdan Marculet, Mircea Farcau, Stefan Mihartescu, Andreea Pantofaru.

Representing a major energy player specialised in renewable energy, in a variety of litigations files against 7 municipalities of Romania in connection with the building tax imposed in connection with wind turbines.

Advising the subsidiary of one of the largest FMGC and cosmetics distributors, on the day-to-day tax matters arising from the recent legislative changes applicable to services invoiced by international key accounts.

Assisting one of the largest international energy companies in connection with a complex fiscal litigation concerning VAT, income tax and depreciation treatment at the level of one of the distribution services subsidiaries and one supply services subsidiary of the group.

Representing the client in negotiations of a protocol between Romanian banks and the central tax authority in relation to exchange of information in situations governed by legal requirements in the fiscal field and situations related to the security and prudence of the banking activity.

Providing assistance to a major beverage distributor regarding the full design and implementation of a new business model involving the distribution of alcoholic drinks.

Assistance and representation to one of the most important names on the pharmaceutical market in Central and Eastern Europe in a highly complex tax inspection and subsequent litigation.

Assistance to a large gambling operator in relation to the existing contractual agreements and drafting a complex memorandum related to the VAT implications derived from the gambling/betting activities performed by the client under partnerships with third parties.

Providing tax and legal assistance to multinational companies in relation to their global employee share plans impacting on their local operations in Romania.

Providing tax advisory services to a multinational corporation active in the automotive sector regarding the setting-up of a service center in Romania.

Specialist lawyer:Alexandru Cristea.