Tax Controversy and Dispute Resolution

Today’s tax controversy landscape represents a perfect storm of competing factors. The Romanian Tax Authorities (RTA) are increasing its enforcement efforts, and focusing on large business tax compliance and international tax issues, for example, introduction of contemporaneous transfer pricing documentation for large taxpayers and the new country-by-country reporting requirements.

Audits are becoming more contentious and the RTA are challenging taxpayers more aggressively due to revenue demands. Practice shows that an increased number of transfer pricing audits and assessments end up in expensive litigation.

Undergoing tax litigation dispute is one of the most challenging times for any organization, particularly because of the continuous evolving uncertainty and the high stakes involved. Therefore, it is of utmost importance that the tax litigation is handled by professional experts who can navigate disputes tactfully and seamlessly. PwC Romania has a dedicated team of specialists to offer effective, practical solutions to clients focused on managing/ resolving tax disputes.

Our services encompass representing the clients and providing expert advice/ opinions in all stages of TCDR starting with assistance during tax audits and continuing with litigation in court.

We can help you with:

We can work with you during the pre-audit prevention phase to achieve successful results by:

reviewing your transfer pricing policies;
reviewing your transfer pricing supporting documentation;
assisting in transactional due-diligence to identify tax audit and controversy risks and exposures;
carrying on pre-audits to identify transfer pricing and tax audit impacts;
once risks are identified, develop and implement other options to the current business model to mitigate your company's risk profile;
training your company personnel.

In Romania, a tax audit can be intimidating for the uninitiated. However, the audit process can be easier with proper preparation and the right advice. We can help you in managing and responding to investigations, audits, and examinations initiated by tax authorities worldwide in order to resolve disputes efficiently and favourably. This notably includes:

tax authority procedural review;
routine and complex audit management related to information requests;
support in document production;
assistance in discussions with the tax authorities.

If your tax dispute is not resolved, we can provide you with a full range of dispute resolution options, including:

drafting objections to acts, complaints related to resolutions based on results of tax audits;
submission of pre-litigation claims with the tax authorities;
preparation of litigation support for court proceedings;
representing clients in all judicial instances;
check of opportunity to use Arbitration Convention and Mutual Agreement Proceedings to resolve transfer pricing disputes.