Corporate tax advisory is a critical first step for any company managing tax obligations that vary across industries and business sectors.
WHY IT MATTERS
In most companies, tax issues arise when a business decision is made without fully understanding its implications and the potential tax exposure involved.
An international expansion, a reorganization, an investment, an intra-group transaction, a dividend distribution or an ANAF tax audit. All are business decisions, but each carries tax implications that may affect the cost, timing or even the viability of a strategy.
NOA Group provides corporate tax advisory services across the full spectrum of direct and indirect taxes - corporate income tax, dividend tax, withholding tax, local taxes, VAT, excise duties and customs duties - assessed from both a Romanian and international tax perspective whenever required by the client’s operations.
At NOA, tax advisory is not about interpreting legislation in isolation. It is about turning tax complexity into a clear decision-making framework for management.
We work alongside entrepreneurs, CFOs, CEOs and international groups, directly with our clients’ finance and management teams, in an environment where tax rules are constantly evolving and the consequences of a poor decision can extend far beyond the impact of an additional tax liability.
When identified early, tax risk can be managed before it becomes a compliance issue. Every NOA recommendation is built around the same objective: providing clarity when the stakes are high.
tax advisory
As companies grow, taxation is no longer a purely domestic matter, making international tax advisory increasingly relevant.
An investment in another jurisdiction, a foreign shareholder, an international restructuring or even the provision of cross-border services can raise questions that cannot be answered under a single body of tax law.
Where is tax due? How do double tax treaties apply? What does tax residence mean in a cross-border context? What structure supports the company’s business objectives without creating unnecessary tax exposure?
NOA Group’s international tax advisory services start with these questions and develop answers that work in practice, not just in theory.
We assist local companies and international groups with the interpretation of double tax treaties, the application of tax residence rules and compliance requirements related to international transactions.
Our experience is further strengthened by the collaboration between our teams in Bucharest and Cluj and NOA’s London office, enabling us to approach international projects within a real operational context rather than solely through the wording of the legislation.
In these engagements, the differentiator is not how many provisions of tax law one knows. It is the ability to align different tax regimes around a single business decision.
fiscal clarity
Companies do not need tax advisory services only when a problem has already arisen. The most important tax decisions are usually those made before the risk becomes visible, which is why most NOA Group engagements begin before a transaction, a reorganization or a tax audit.
NOA’s tax advisory services cover the full lifecycle of a company’s tax-related decisions:
Each of these areas is led by certified tax advisors with in-depth experience in their respective fields of practice.
We believe taxation has become too complex to be addressed effectively through generalist expertise. At the same time, technical expertise, however strong, is not enough.
A tax recommendation creates value only when it can be implemented, supports the company’s objectives and can withstand subsequent scrutiny.
This is why NOA teams work directly with management and clients’ finance departments, integrating tax analysis into the broader context of strategic decision-making.
In practice, this means we are involved not only when a tax provision needs to be interpreted, but also when a client is assessing an investment, preparing an acquisition, restructuring a group or planning expansion into a new market.
For us, tax advisory is not a compliance exercise. It is an integral part of a well-informed business decision.
Rigor is not separate from strategy
Few areas of taxation evolve as rapidly as VAT.
For many companies, the risk does not arise from a lack of knowledge of the legislation, but from the fact that the same transaction may receive different VAT treatments depending on the context in which it is assessed.
Expansion into a new market. A change in the logistics chain. An intra-Community supply. An import. An operational restructuring.
Each of these can change the applicable VAT treatment and give rise to obligations that may only become apparent during a tax audit. This is why we intervene before those risks materialize.
Our VAT advisory services cover the entire lifecycle of a transaction: VAT registration, including for non-resident companies carrying out transactions in Romania; the VAT treatment applicable to domestic and intra-Community transactions, imports and exports; as well as VAT recovery for amounts overpaid or incorrectly treated as non-deductible
We do not view VAT as a compliance exercise, but as an integral part of how a company operates.
When a client enters a new market, changes its logistics flows or launches a different business model, we recommend reviewing the VAT structure before implementation. In most cases, the most effective solution is the one identified before the first transaction, not after the first tax audit.
Assistance
A tax audit does not only test a company’s documentation. It also tests the company’s ability to substantiate its own decisions. Our experience shows that the difference between an efficiently managed audit and one that creates operational disruption does not depend exclusively on the strength of the tax arguments. It also depends on how the company responds, documents its position and manages its dialogue with the tax authority.
At such times, our role is to bring clarity and structure to a process that can quickly become demanding in terms of both time and resources.
NOA represents the client throughout the tax audit, coordinating communication with ANAF inspectors and ensuring that the audit is conducted in accordance with the applicable legal framework.
In parallel, we independently assess the identified tax exposures and work with management to develop the response strategy, ensuring that each decision taken during the audit is supported from both a legal and an economic perspective.
Where the audit results in the issuance of a tax assessment decision, we assist the client during the administrative appeal stage and work alongside lawyers specializing in tax litigation where the matter needs to proceed before the courts.
For us, the transition from advisory to litigation does not mean a change in strategy or team. It is the continuation of the same approach.
Income Tax
At first glance, corporate income tax may appear to be one of the most predictable tax obligations. In practice, it is one of the areas in which business decisions most frequently generate long-term tax consequences.
The tax treatment of an investment. Sponsorship policy. Financing structure. Relationships with related parties. Provisions. Reorganizations. Each of these decisions affects the taxable base and, consequently, the company’s tax risk profile.
Our role is to build a tax structure that accurately reflects the economic substance of the business and can be sustained over time.
NOA provides advisory services on corporate income tax calculation and reporting, the deductibility of expenses and the identification of tax incentives applicable to each business model.
For companies investing in research and development, manufacturing or profit reinvestment, we assess the opportunities available under the legislation and how they can be integrated into a coherent tax strategy.
Tax optimization does not mean artificially reducing taxes. It means making decisions that remain sustainable over time, from both an economic and a tax perspective.
Transfer Pricing
As corporate groups become increasingly integrated, transfer pricing is no longer simply a compliance requirement.
It has become one of the most important areas of tax governance.
Tax authorities are subjecting related-party transactions to increasing scrutiny, and transfer pricing documentation must demonstrate not only compliance with the arm’s length principle, but also the economic rationale underlying the group structure.
NOA has a dedicated transfer pricing team with more than 15 years of experience in preparing transfer pricing documentation, conducting benchmarking analyses and delivering projects aligned with OECD standards and BEPS principles. Over the years, we have assisted more than 200 companies in preparing documentation relating to related-party transactions.
Beyond preparing the documentation itself, we review existing group-level transfer pricing policies, update files from previous years and assist companies in preparing Advance Pricing Agreements (APAs).
Our experience has shown that the best outcomes do not arise when transfer pricing documentation is prepared under the pressure of a deadline imposed by the authorities.
They arise when the transfer pricing policy is developed alongside the business model. That is the difference between compliance and planning.
Tax Due Diligence
The most costly tax risks are often those a buyer does not identify before signing a transaction. Financial statements tell the story of the past. Tax due diligence identifies whether there are exposures that could affect the future value of the investment.
In any acquisition process, the question is not only what am I buying? It is also what tax liabilities am I acquiring together with the company?
NOA assists both buyers and sellers in tax due diligence processes, assessing risks that may influence the transaction structure, purchase price adjustment mechanisms or contractual warranties.
From the buyer’s perspective, we assess existing tax exposures and quantify their financial impact before transaction closing.
From the seller’s perspective, we prepare the company for the due diligence process so that potential risks are understood and managed before they affect negotiations.
The results of the tax analysis do not remain confined to a technical report. They contribute directly to price negotiations, the structure of the sale and purchase agreement and decisions regarding post-acquisition integration.
In our experience, valuable due diligence does more than identify risks. It prioritizes them. It quantifies them. And it gives management sufficient information to make an informed decision.
Industries We Serve
Tax legislation may be the same. The business context is not.
The same rule can have entirely different consequences for a technology company, an industrial group or an infrastructure operator. This is why we believe tax expertise cannot be separated from an understanding of the underlying business model.
In recent years, the NOA team has assisted companies across technology, manufacturing, retail, FMCG, infrastructure, logistics and energy, adapting its tax recommendations to the specific characteristics of each industry and operating model.
Our experience across different sectors enables us to anticipate potential risk areas as early as the planning stage, rather than turning the process into an exercise in discovery during a tax audit.
Companies we have worked with include AROBS, Evozon, Nagarro iQuest, Hochland, Macromex, Rombat, RMB Interauto, COSCO Shipping, E-Infra and Electrogrup.
We do not view these projects as a collection of industries. We view them as experience accumulated across different decision-making contexts, which we bring to every new engagement.
Tax Advisory
The NOA model is built around this belief.
Clients work directly with the partners leading the engagement and taking ownership of the recommendations provided. We believe that, in complex projects, experience cannot be delegated.
Tax rarely exists in isolation. A tax decision may affect a transaction, an audit process, a restructuring or an international expansion. This is why we collaborate across our areas of expertise to provide recommendations that take the full business context into account.
Compliance with the law is essential. But compliance is the outcome of a well-informed decision, not an end in itself. We always begin with the question management is trying to resolve and build our tax recommendations around it.
Most of our engagements do not begin during a tax audit. They begin long before that. We are involved at the moments when companies grow, invest, reorganize or enter new markets. This is why many of our clients consult us before a tax issue arises. Not because they have to. But because they prefer to make decisions with greater clarity.
From our clients
“When I'm asked who we work with for tax and internal audit, I say NOA. I'm not even asked why — it's intuitive. NETOPIA is what it is, so NETOPIA's consultants are at the same level.”
faqs
Ideally, before an important decision is implemented. A reorganization, an investment, an international transaction or a change in the business model are all situations in which tax implications can significantly influence the final outcome.
No.
We work with international groups and growing entrepreneurial companies, as well as organizations dealing with a complex tax project for the first time. The complexity of the engagement is more relevant than the size of the company.
Yes.
We represent clients throughout the tax audit, coordinate communication with the authorities and work together to develop the response strategy. Where necessary, we continue to provide assistance during the administrative appeal stage and collaborate with lawyers specializing in tax litigation.
We start with the decision the client needs to make. Tax expertise is how we support that decision, not the ultimate purpose of the engagement.
Yes.
We assist companies with cross-border operations and investments on matters involving tax residence, double tax treaties, international structures and compliance requirements related to transactions across jurisdictions.
