Tax Advisory in Romania for Chinese Clients
Chinese groups usually need advice on the China–Romania double tax treaty, service fees paid to the parent and documentation of intra-group pricing.
Typical matters for Chinese clients
Chinese groups usually need advice on the China–Romania double tax treaty, service fees paid to the parent and documentation of intra-group pricing.
- China–Romania double tax treaty
- Withholding on service fees and royalties
- Transfer-pricing documentation
- Customs and VAT on imports from China
Rules for a non-EU party from China
Outside the EU, the double tax treaty between China and Romania and the Romanian Fiscal Code (Legea 227/2015) are the main framework; EU directives do not apply to the Chinese party.
Documents and cross-border formalities
Since China joined the 1961 Apostille Convention in November 2023, Chinese public documents are apostilled instead of consular-legalised; they are then translated into Romanian by an authorised translator. Mainland China applies the Apostille Convention since 7 November 2023; apostilles are issued by the Ministry of Foreign Affairs or authorised local foreign-affairs offices. Documents are served under the 1965 Hague Service Convention.
- Corporate documents of the Chinese limited liability company
- Power of attorney for remote signing
- Authorised Romanian translations
- Beneficial-owner declaration (Legea 129/2019)
People and staff
Chinese nationals need a work permit from IGI and a long-stay visa for employment, followed by a residence permit.
What a tax advisory engagement covers
Romanian tax advice for a foreign client always combines three layers: the Romanian Fiscal Code (Legea 227/2015), the applicable double tax treaty and, for EU parties, the relevant directives. We work through all three before giving an answer.
- Corporate income tax and the micro-enterprise regime eligibility check
- Withholding tax on dividends, interest, royalties and service fees
- VAT registration, intra-EU supplies and reverse-charge mechanics
- Transfer-pricing documentation for related-party transactions
- Permanent-establishment analysis for staff working in Romania
- Replies to ANAF queries and assistance during tax audits
Tax issues that catch foreign groups by surprise
Romanian tax practice has particularities that differ from what groups expect from their home jurisdiction. These are the recurring ones.
- Withholding applied because a tax-residence certificate was missing or expired
- Intra-group services invoiced without supporting documentation
- VAT registration triggered later than the law requires
- Treaty benefits assumed without checking the current treaty text and protocol
How It Works
Fact review
We map entities, flows and residence of each party.
Legal analysis
We apply the Fiscal Code, treaty and EU rules to each flow.
Documentation
We prepare memoranda, residence-certificate checklists and contracts.
Ongoing support
We monitor changes in Romanian tax law and update the analysis.
How we work with Chinese clients
Scope, stages and documents are agreed in writing before work starts.
- Legal activity since 2008 — 18 years of experience
- Remote process for Chinese clients with power of attorney
Phone
+40 740 011 411Response Time
Mon–Fri 10:00–16:00
Schedule
Mon – Fri: 10:00 – 16:00
Frequently Asked Questions
Discuss your Chinese matter
Cabinet de Avocatură Pantilimon Rikhárd-Árpád, Târgu Mureș. Office hours: Monday–Friday, 10:00–16:00.