For companies with cross-border operations and clients with interests in several jurisdictions: structuring, compliance and defence in international taxation, grounded in ADIT training (in progress).
For a company with cross-border activity or a person with interests in several countries, taxation becomes a multi-layered terrain: Romanian law, the law of the other state, double-taxation treaties and, increasingly, European and international anti-avoidance rules.
Mistakes in this field are costly and hard to correct retroactively: an undocumented transfer-pricing structure, an overlooked permanent-establishment risk, an uncertain tax residence or foreign-source income not correctly declared can generate obligations in two jurisdictions at once, plus penalties.
The international-taxation component of my practice rests on ADIT training — the Advanced Diploma in International Taxation of the Chartered Institute of Taxation in London, the globally recognised standard in the field, currently in progress — and on membership of the specialist international networks.
Also in the international sphere, for assets with a cross-border element, there is a page dedicated to international trusts and wealth structuring.
The pricing policy between related entities, preparing and defending the transfer-pricing file, assistance in the face of the tax authority's adjustments.
Determining residence for individuals and companies, residence conflicts between states and their consequences for the taxation of income.
Assessing the risk that a cross-border activity creates a taxable permanent establishment and the tax implications that follow.
Applying double-taxation treaties and the mechanisms for eliminating it — tax credit, exemption — so that you do not pay twice.
The correct tax treatment of income obtained outside the country and the declaration obligations in Romania.
The tax analysis of holdings and structures with an international element, from the perspective of Romanian law and the anti-avoidance rules.
The main risk areas are transfer pricing (how the two related companies invoice each other), the permanent-establishment risk and the tax treatment of the flows between them. An initial analysis identifies the exposure and the solutions, before an audit does it for you.
It depends on your tax residence, the nature of the income and the applicable treaty between the two states. There are situations in which obligations arise in both jurisdictions, and the double-taxation treaty establishes how the double taxation is eliminated. Each case requires individual analysis.
It is the situation in which a company from one state carries out, in another state, an activity substantial enough to become taxable there too, even without having a formal subsidiary. For companies with cross-border activity, it is one of the most frequently overlooked risks.
ADIT — the Advanced Diploma in International Taxation — is the specialist diploma of the Chartered Institute of Taxation in London, recognised globally as the standard in international taxation. It is a qualification in progress, involving rigorous training, beyond national law, in the principles and mechanisms governing cross-border taxation.
The diploma is built from three examinations, and the modules chosen reflect my areas of practice directly: Principles of International Taxation (the foundational module — treaties, residence, anti-avoidance, the BEPS framework), Transfer Pricing (after the OECD and UN models) and the United Kingdom option (international taxation in relation to the UK) — the latter closely linked to international clients and to trust practice.
An initial analysis clarifies the cross-border tax exposure and the available solutions, from the perspective of Romanian law and the applicable treaties.