In-depth analysis on Romanian and international taxation, ANAF disputes, white-collar defence, wealth structuring and cross-border succession — written for an international audience. Practical, source-based, kept current.
The full set of English-language analyses. Choose a field to narrow the list.
18 July 2026
Leaving Romania does not move your taxes automatically. Residence criteria, the departure questionnaire, dual residence and how ANAF checks in 2026.
18 July 2026
How Romania's double taxation treaties work: residence certificate, source rates, ordinary credit, beneficial owner, the PPT and the mutual agreement procedure.
18 July 2026
Working remotely from Romania for a foreign employer: income tax, social contributions, the A1 certificate, the digital nomad visa and VAT for freelancers.
18 July 2026
Foreign dividends, interest and capital gains: how a Romanian resident declares them in the annual return, the foreign tax credit, CASS thresholds and losses.
18 July 2026
Property abroad and Romanian tax: foreign rent, credit vs exemption, the sale taxed on price not gain, CASS thresholds and how ANAF learns via DAC1 and DAC7.
18 July 2026
Moving your Romanian company abroad? Place of effective management, 16% exit tax, CFC rules and real substance — what works legally in 2026 and what fails.
18 July 2026
The A–E hallmarks, the main benefit test, who reports and when the duty shifts to you. The 30-day deadline and penalties under Romanian tax procedure.
18 July 2026
The common-law trust and the Romanian fiducia (arts. 773-791 Civil Code): why the fiducia cannot pass wealth to children, and when each structure is used.
18 July 2026
Romania is not party to the 1985 Hague Convention. How Romanian law treats a foreign trust, what a resident beneficiary declares, and why the reserve holds.
18 July 2026
Liechtenstein Stiftung, Dutch STAK, Panama foundation: what a family foundation offers a Romanian resident, and what it cannot change for assets in Romania.
18 July 2026
How a Romanian resident is taxed as settlor, beneficiary and on the structure itself: the 10% and 70% rates, CFC rules, effective management and CRS.
18 July 2026
The EU Succession Regulation 650/2012: one law for your whole estate, professio juris, forced heirship, and the US estate-tax trap for foreign heirs.
18 July 2026
Romania's forced heirship (rezerva succesorală, art. 1086-1092 Civil Code): who the reserved heirs are, how much they take, and why no trust or gift escapes it.
18 July 2026
The European Certificate of Succession (art. 62+ Reg. 650/2012): what it proves, who issues it in Romania, its effects and the six-month validity trap.
18 July 2026
What remains legal in offshore structures after BEPS, ATAD and CRS. The tests applied in 2026, what fails systematically, and when a structure works.
18 July 2026
The Romanian holding regime in 2026, what Dutch, Cypriot, Luxembourg or Maltese holdings still offer, and the criteria that really decide the choice.
18 July 2026
UAE corporate tax, the free-zone regime, tax residence and the Romania–UAE treaty. What it means, concretely, for a Romanian with a company in Dubai.
18 July 2026
The Estonian model is deferral, not zero tax. The real 2026 rates, what e-Residency does not do, and the honest arithmetic against a Romanian SRL.
18 July 2026
The EU list of non-cooperative jurisdictions after the February 2026 update, its real tax effects in Romania and the myth of the 50% withholding rate.
18 July 2026
Economic substance is not an address and a nominal director. What tax authorities check, which evidence counts, and what ANAF does when substance is missing.
18 July 2026
Romania's CFC rules (art. 40⁵ Fiscal Code): who is caught, which income is attributed, the substance exception and why individuals fall outside them.
18 July 2026
Beneficial owner for tax vs UBO for AML: what the Danish cases settled, how ANAF denies withholding relief, and how the right to dispose of income is proved.
18 July 2026
How the place of effective management makes a foreign company Romanian tax resident on worldwide profit — the statutory test, the evidence and the defence.
18 July 2026
Who is a beneficial owner, when the UBO declaration is filed, what CJEU C-37/20 changed for public access, and what the 2024 EU AML package brings by 2027.
18 July 2026
Who must prepare Romania's transfer-pricing documentation file under OPANAF 828/2026, the per-transaction thresholds, filing deadlines and audit risks.
18 July 2026
The five transfer-pricing methods — CUP, resale price, cost plus, TNMM, profit split — with examples, how the method is chosen and what ANAF checks.
18 July 2026
How transfer-pricing adjustments arise, why ANAF adjusts to the median, how double taxation is eliminated through MAP, and how the position is defended.
18 July 2026
Why management fees are ANAF's favourite target, the OECD two-step test, shareholder activities, the documentation that saves the deduction, and fatal errors.
18 July 2026
Interest on a loan from the parent must be arm's length. The transfer-pricing test, the ATAD deductibility cap and the non-deductible portion, explained.
18 July 2026
The benchmarking study is the core of the transfer-pricing file: comparable selection, the interquartile range and why ANAF adjusts to the median.
18 July 2026
Without a transfer-pricing file, ANAF estimates ex officio and adjusts to the median. The fine is the small part; the estimate is the real problem.
18 July 2026
An advance pricing agreement blocks adjustment on covered transactions: when it pays, the types, procedure and cost, under OPANAF 827/2026 with roll-back.
18 July 2026
How the group is defended when ANAF targets intra-group transactions: lines of defence, what the inspector attacks, the draft-report reply and MAP.
18 July 2026
Too small for transfer pricing? A myth. The duty comes from association, not size: a small subsidiary's risks and the minimum documentation it needs.
18 July 2026
Transfer-pricing adjustments can reach millions. How a party-appointed tax expert challenges the method, comparables and benchmarking under OPANAF 828/2026.
18 July 2026
How your foreign accounts and income reach ANAF automatically through CRS/DAC2 — what Romanian residents must declare, and how to regularise before an audit.
18 July 2026
From 6 July 2026, ANAF Antifraud inspectors can run personal wealth checks and issue assessments directly — including the 70% tax on unjustified income.
18 July 2026
What tax due diligence uncovers before a Romanian acquisition: hidden liabilities, transfer-pricing adjustments, VAT, joint liability. Share vs asset deal.
18 July 2026
How a family holding isolates business risk, the tax exemptions it offers in 2026, what it can never do, and the errors that turn it into a vulnerability.
18 July 2026
An SRL does not protect your personal wealth as much as you think. The four real breaches, the principles of separation, and what can still be done legally.
These analyses are informational and do not constitute legal or tax advice.