Impozitul pe veniturile obținute din România de nerezidenți: un hot-topic în cadrul controalelor fiscale
Tax on income obtained from Romania by non-residents: a hot topic in the recent anƟ-fraud checks

Summary/Abstract: Recently, numerous anti-fraud checks have been conducted by the tax authorities, targeting the tax treatment applied by companies to income earned from Romania by non-residents. Although this type of income is, in some cases, exempt from taxation (either under the provisions of the Fiscal Code or under Double Taxation Treaties concluded by Romania with other countries or under European Directives), the fiscal authorities have sometimes reclassified such transactions,changing the applicable tax treatment and requiring additional tax to be paid. In this article, we will present the main factors which can lead to the reclassification of transactions with non-resident companies and thus to unfavorable taxtreatment in the event of a tax audit.

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