Taxation · area of practice

Taxation, from prevention to litigation.

Tax advice for companies, assistance and representation in disputes with the tax authority, and international taxation — coordinated by an attorney who is, at the same time, a tax adviser and a forensic tax expert.

Context

Taxation does not forgive improvisation.

For a company, taxation is the area where a seemingly minor decision — an invoice, a classification, a transaction between related parties — can turn, years later, into a major payment obligation, with interest, penalties and, sometimes, a criminal file.

In recent years the tax authority has become significantly more aggressive and far better equipped technically. Audits are more frequent, more thoroughly documented and frequently end with considerable amounts, recalculated retroactively. In such a context, taxation ceases to be a purely accounting matter and becomes, in equal measure, a legal one: what can be proven, which classification holds, which deadlines are running.

My tax practice starts from a simple conviction: most serious tax problems could have been prevented, and those that do reach litigation are won on technical substance, not on procedural formulas. This requires someone who understands both the figure and the rule — exactly the convergence of the three capacities I bring together.

Florin Hrițuliac, tax adviser
Florin Hrițuliac
Areas of practice

Three directions covering the entire tax cycle.

From the correct structuring of an operation, before any audit, to arguing the case before the administrative court. The same technical expertise, throughout.

Tax advice

Ongoing or one-off assistance for companies: lawful optimisation of the tax position, opinions on specific matters, compliance, assistance during a tax audit.

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Tax litigation

Challenging the tax assessment, administrative tax litigation against the authority, suspension of the enforcement of established obligations.

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International taxation

Transfer pricing, tax residence, permanent establishment, double-taxation treaties — for companies with cross-border operations.

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Party-appointed tax expertise

Critical analysis of expert reports, technical opinions and party-appointed expert adviser — the technical rebuttal of an unfavourable tax calculation, by a forensic tax expert.

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Taxation for individuals

Review of personal tax position, unexplained wealth, reclassification of sole traders, transactions reclassified by the authority. Defence for individuals.

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Taxation for companies

Economic substance of transactions, deductibility, disguised dividends, shareholder loans, tax risk in the era of SAF-T and e-Invoicing.

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Director liability

Joint liability for company debts, liability in insolvency and protecting the personal assets of the director and shareholder.

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For attorneys and law firms

Party-appointed expert, fast out-of-court expert reports and specialist support on taxation, transfer pricing and economic criminal matters — collaboration worldwide.

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For accountants and accounting firms

The accountant's legal-tax partner: tax audits, challenges, litigation and advice on difficult matters, in support of your relationship with the client.

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International trusts and wealth structuring

Trusts and foundations across multiple jurisdictions, cross-border succession, the taxation and defence of international trusts. STEP-network consultant, specialising in trusts.

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Why the combination matters

The tax substance and the defence, in the same person.

Ordinarily, a complex tax problem calls for an adviser for the figures and an attorney for the procedure. Between the two perspectives, things get lost in translation, delays and double costs arise — and sometimes the decisive technical argument is lost precisely at the border between the two professions.

Here, the three capacities come together in one person. The same grasp of the tax base informs, case by case, the advice, the expert report or the defence — each exercised separately, in the capacity the case calls for, never combined within the same file. Added to this is over twenty years of experience in business, bringing an understanding of the real economic context of each operation.

Tax adviser

Chamber of Tax Advisers

Tax attorney

Litigation and representation — Brașov Bar

Forensic tax expert

The expert report as evidence — Ministry of Justice

ADIT (in progress)

Advanced Diploma in International Taxation — a leading qualification in international taxation, awarded by CIOT London (Chartered Institute of Taxation). Modules: International Taxation, Transfer Pricing and the United Kingdom option — a specialisation in UK taxation, valuable in trust structuring and asset protection, as well as for companies with EU–UK or international operations.

How a collaboration unfolds

From the first conversation to resolution.

Stage 01

Assessing the situation

A first conversation establishes the nature of the problem, the deadlines that are running and the real stakes. Honest and realistic — sometimes the conclusion is that you do not need litigation, but a correction.

Stage 02

Strategy

Depending on the case: structuring an operation, preparing for an audit, building a challenge or a court action. With a clear estimate of the prospects.

Stage 03

Execution and representation

Drafting the documents, representation before the tax authority or the court and, where appropriate, presenting the tax expert report — all coordinated by the same person.

Frequently asked questions

What clients usually ask.

When should I turn to a tax attorney — before or after an audit?

Ideally, before. Most serious tax problems can be prevented through correct structuring and rigorous documentation, done in good time. A preventive consultation costs a fraction of what later litigation would cost.

If you have already received an audit report or a tax assessment, the time is now: the deadlines for challenging run from the date of communication and are short. The earlier you act, the greater the room for manoeuvre.

What is the difference between a tax adviser and a tax attorney?

The tax adviser deals with the technical substance — the calculation of obligations, the classification, lawful optimisation. The attorney deals with the legal side and with representation before the court. In complex matters, you need both perspectives.

The advantage of combining the two capacities in the same person is that nothing is lost at the border between them: the technical argument is built from the outset with its legal use in mind, and the legal defence rests on a real understanding of the figures.

Can I challenge a tax assessment if the deadline already seems to have passed?

It depends on the situation. The deadline for challenging generally runs from the communication of the document, and meeting it is essential. There are, however, situations in which the communication was flawed or in which other procedural avenues exist.

This is why the first assessment matters even when you believe it is too late — sometimes it is not, and at other times at least the assets can be protected against enforcement.

Do you also work with clients outside Brașov?

Yes. Services are available internationally. Consultations can take place by phone, by video conference or in writing, in addition to meetings at the office. For a well-documented tax matter, distance is not a barrier.

How is the fee determined?

Depending on the nature and complexity of the matter, communicated transparently before the collaboration begins. It may be a fixed fee for a piece of work, in stages for litigation, or an ongoing retainer-type collaboration for companies. The first conversation clarifies the appropriate form.

Contact

Do you have a tax problem or a tax assessment?

A first conversation clarifies the situation, the deadlines that are running and the real options — whether the matter is prevention, litigation or an international operation.

E-mailrolegal@pm.me
Phone+40 799 597 410
AvailabilityInternational · video or in person