Romania

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Practice area

World TP Reviews

Transfer pricing
Deloitte

Deloitte provides corporate and international tax, indirect tax, global employer services and transfer pricing. Just in 2017, it advised more than 800 clients, many of which were large Romanian companies. The team focuses on industries such as retail, manufacturing, energy and resources, FSI, real estate and pharma.

The transfer pricing department advised a manufacturing client on obtaining an APA. The value of the transaction was approximately $500 million. It required an in-depth understanding of the client’s business and accounting rules. The team developed a pricing methodology that could be applied for intragroup transactions in the long run. It implemented an innovative component concerning specific search strategies and formulating a variable pricing methodology varying with each transaction. In this case, checks and the criteria were figured out in order to sufficiently comply.

EY

The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by Oslo-based partner Sveinung Baumann-Larsen, it brings together multi-disciplinary experience and resources focused on IT, accounting, and tax from the entire region in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals, to name but a few.

Grant Thornton

Grant Thornton opened its office in Romania in 2010, proving all business clients advisory in assurance, tax and outsourcing services. Nadia Oanea heads the tax department and has more than 18 years of experience in local and international taxation. 

Oanea led her team in multiple transfer pricing cases recently, from transfer pricing audit challenges from the tax authority to producing transfer pricing documentation for compliance. The transfer pricing team is advising various multinational clients producing Country-by-Country Reporting (CbCR) documentation, which involved submitting a notification to the Romanian tax authority regarding the parent company, who is registered in another country that does not have CbCR agreement with Romania, and advising on the implication and collecting data. She also led the transfer pricing team advising a subsidiary of a pharma-international group registered in India. Grant Thornton’s role was to review the local transfer pricing documentation in accordance with the local transfer pricing regulation.

Nestor Nestor Diculescu Kingston Petersen

Nestor Nestor Diculescu Kingston Petersen was founded in 2008 and has more than 40 lawyers and consultants advising in tax legal. The team in Bucharest consists of 20 lawyers and consultants. Marius Ionescu and Alina Timofti, who have comprehensive tax experience, are co-heads of the tax department. The team focuses on tax areas such as corporate, indirect, individual taxation, withholding, property social security contributions, transfer pricing services and capital gains.

The firm is advising a large industrial manufacturer in a complex cross-border restructuring project that involved a substantial move of production facilities from another country to Romania. There are complex restructuring tax aspects in the area of corporate tax and transfer pricing.

Taxhouse

Angela Rosca is the managing partner and founder of Taxhouse. She has 23 years of experience advising on local and international taxation and specialises in transactional, indirect tax, M&A, planning and more. The firm has specific expertise in investment structuring, real estate, M&A, due diligence, VAT, corporate income tax and capital gains tax compliance. As part of the Taxand independent organisation, the firm has access to member tax practitioners in 50 countries.

Rosca is leading numerous transfer pricing compliance cases for domestic and non-resident clients. One of the cases in progress involves Rosca’s team drafting the transfer pricing documentation for numerous local and foreign intra-group transactions. The team is analysing several intra-group transactions covering several years.

TaxWise

TaxWise began its tax advisory services in 2014, offering various tax legal services and more emphasis in transactional tax and due diligence reporting. Lavinia Bartos is the transfer pricing partner. The recent development in transfer pricing matters has increased demand from clients requiring advice. It has responded to this by increasing its focus on transfer pricing advisory with its team of seven dedicated transfer pricing members.

The firm assisted a local company during its audit by the tax authority after TaxWise had prepared the transfer pricing files. The team’s role was to support the analyses and conclusions in the transfer pricing files. It has also been representing multiple clients during their transfer pricing audits, for which the team had to produce transfer pricing files.