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ANAF controls on fixed and permanent establishments

  • The National Agency of Tax Administration (ANAF) is planning audits to check if non-resident taxpayers have permanent or fixed establishments in Romania.
  • ANAF will use risk analyses to identify high-risk taxpayers who have not registered for tax purposes.
  • This issue is important both nationally and internationally, and is on the agenda of the OECD and other member states.
  • ANAF is preparing a first audit campaign for non-resident taxpayers, followed by a second campaign for Romanian resident taxpayers with activities or income in other member states.
  • The audit process is thorough and includes assessing all relevant documents. According to legislation, a non-resident generates a permanent establishment if they have the resources to regularly supply goods or services in Romania, while a permanent establishment is where all or part of their activities are carried out, directly or through a dependent agent.

Source PwC

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