Tax Advisory in Romania for Japanese Clients
Japanese groups ask about the Japan–Romania double tax treaty, taxation of seconded managers and transfer pricing for component supply.
Typical matters for Japanese clients
Japanese groups ask about the Japan–Romania double tax treaty, taxation of seconded managers and transfer pricing for component supply.
- Japan–Romania double tax treaty
- Taxation of seconded employees
- Transfer pricing for component supply
- Customs and VAT on imported equipment
Rules for a non-EU party from Japan
Outside the EU, the double tax treaty between Japan and Romania and the Romanian Fiscal Code (Legea 227/2015) are the main framework; EU directives do not apply to the Japanese party.
Documents and cross-border formalities
Japanese corporate documents are apostilled by the Ministry of Foreign Affairs and translated into Romanian by an authorised translator. In Japan the apostille is issued by the Ministry of Foreign Affairs; notarised documents may need prior certification by the Legal Affairs Bureau. Documents are served under the 1965 Hague Service Convention.
- Corporate documents of the Japanese kabushiki kaisha (KK)
- Power of attorney for remote signing
- Authorised Romanian translations
- Beneficial-owner declaration (Legea 129/2019)
People and staff
Japanese managers need a work permit (or secondment permit) and a long-stay visa, 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 Japanese clients
Scope, stages and documents are agreed in writing before work starts.
- Legal activity since 2008 — 18 years of experience
- Remote process for Japanese 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 Japanese matter
Cabinet de Avocatură Pantilimon Rikhárd-Árpád, Târgu Mureș. Office hours: Monday–Friday, 10:00–16:00.