The Director of the National Tax Information issued an interpretation stating that the transformation of perpetual usufruct into ownership by a local government unit does not constitute a separate transaction subject to VAT. This interpretation is based on the regulations introduced in 2023. It also considers that the transformation does not affect the “control over the thing” obtained before May 1, 2004, and therefore cannot be treated as a repeated delivery subject to tax on goods and services. However, it is important to note that different rules apply to transformations based on statutory law compared to those based on the parties’ agreement.
Source Deloitte
