Tax Advisory in Romania for South Korean Clients
Korean groups focus on the South Korea–Romania double tax treaty, toll-manufacturing models and VAT on imported components.
Typical matters for South Korean clients
Korean groups focus on the South Korea–Romania double tax treaty, toll-manufacturing models and VAT on imported components.
- South Korea–Romania double tax treaty
- Toll and contract manufacturing models
- VAT and customs on components
- Transfer-pricing files
Rules for a non-EU party from South Korea
Outside the EU, the double tax treaty between South Korea and Romania and the Romanian Fiscal Code (Legea 227/2015) are the main framework; EU directives do not apply to the South Korean party.
Documents and cross-border formalities
Korean corporate documents are apostilled and translated into Romanian by an authorised translator. In South Korea the apostille is issued by the Ministry of Foreign Affairs (or the Ministry of Justice for certain public documents). Documents are served under the 1965 Hague Service Convention.
- Corporate documents of the South Korean chusik hoesa
- Power of attorney for remote signing
- Authorised Romanian translations
- Beneficial-owner declaration (Legea 129/2019)
People and staff
Korean specialists need a work 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 South Korean clients
Scope, stages and documents are agreed in writing before work starts.
- Legal activity since 2008 — 18 years of experience
- Remote process for South Korean 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 South Korean matter
Cabinet de Avocatură Pantilimon Rikhárd-Árpád, Târgu Mureș. Office hours: Monday–Friday, 10:00–16:00.