Tax, residency, substance
Genuine relocation,
cleanly sequenced.
For founders restructuring from Germany, the Netherlands, France, or the UK, the move to Romania requires careful sequencing. Tax residency, substance, and exit-tax exposure are interlocking. Get one out of order, the other two cannot repair the damage.
We handle the Romanian-side execution and coordinate with your origin-country counsel so the move is defensible, not improvised.
Four tracks
Corporate, personal,
residency, substance.
A complete relocation runs across four interlocking tracks. We handle each and sequence them so the moves at one level don't undermine the protection at another.
Corporate tax positioning
Structuring the Romanian SRL to take advantage of the right tax regime , microenterprise (1% / 3% on turnover) or standard CIT (16% on profit) , based on your projected revenue, payroll, and activity. We map the regime transitions in advance so the change at the €100K threshold is sequenced, not abrupt.
- Microenterprise vs standard CIT election
- Threshold transition planning (€100K revenue)
- Dividend distribution timing (8% withholding)
- Holding-company layering where genuine
Romanian tax residency certificate
A tax residency certificate is issued by ANAF (Romanian National Fiscal Administration) and evidences that an individual or company is a Romanian tax resident under Romanian domestic law and applicable double-tax treaties. It is the document foreign tax authorities request when a withdrawal-of-residence claim is made.
- ANAF application coordination
- Double-tax treaty mapping
- Certificate translation and apostille (if needed abroad)
- Annual renewal management
Individual residence permits
Non-EU founders relocating to Romania apply for a long-stay visa (Category D) followed by a temporary residence permit (TRP) on economic grounds. The General Inspectorate for Immigration (IGI) issues both. EU citizens register their stay at the local authority , a lighter administrative process. Since January 2025, Romania's Schengen membership extends the practical value of a Romanian residence permit.
- Long-stay visa (D-visa) preparation
- Temporary residence permit (TRP) on economic grounds
- EU registration of residence (lighter regime)
- Renewal and permanent residence pathway
Substance & exit-taxation defence
Several EU jurisdictions , Germany above all , have sharpened exit-taxation rules and will scrutinise whether a relocated founder's Romanian entity has genuine economic activity. Substance is not a checkbox: it is local employment, director presence, documented decision-making, and operational reality. We build structures designed to withstand a third-party audit, not paper structures that invite challenges three years later.
- Substance assessment against German / Dutch / French criteria
- Director presence and decision-making documentation
- Local payroll and operational footprint
- Substance report for cross-border counsel
Engagement
Five phases.
Coordinated.
A relocation typically runs three to nine months end to end. The substance build-out continues for the first three years. We retain the calendar so you don't.
- 01
Discovery & current-state mapping
A focused 30-minute call. You explain your origin jurisdiction, current structure, business activity, and timeline. We map the moving parts , corporate, personal, family , and identify the order in which steps must occur.
- 02
Sequencing memorandum
A written brief specifying: the order of steps (entity formation, capital deposit, personal residence change, tax residency certificate, exit filings in origin jurisdiction), critical dates, and the key risks to manage. This is the document your home-jurisdiction counsel needs to align with.
- 03
Coordinated execution
We execute each Romanian-side step (formation, address, tax residency, residence permit) and coordinate timing with your origin-country tax advisor. Mis-sequenced restructurings are where most exit-tax exposures arise.
- 04
Substance build-out
For founders relocating from high-scrutiny jurisdictions, we put in place the substance evidence trail , local employment, director presence schedule, board minutes, operational records , from day one rather than retrofitting it after a query.
- 05
Annual maintenance
Tax residency certificates renew annually. Residence permits renew on a fixed cycle. Substance documentation is built up over the first three years. We retain the file and manage the calendar.
FAQ
Common questions.
How does Romanian tax residency work?
Under Romanian domestic law, an individual is a Romanian tax resident if they meet one of: (i) Romanian domicile; (ii) centre of vital interests in Romania; (iii) physical presence in Romania for more than 183 days in any 12 consecutive months; or (iv) Romanian citizenship working abroad as a Romanian government employee. For companies, Romanian tax residency follows place of management or registered office. Tax residency is then mediated by any applicable double-tax treaty.
Can I become a Romanian tax resident without giving up my home country residence?
Possibly, in dual-residence cases. The applicable double-tax treaty contains tie-breaker rules , permanent home, centre of vital interests, habitual abode, nationality , that determine which country has primary taxing rights. Dual-residence positions are workable but require careful documentation; in practice, most founders find it cleaner to make a definitive break rather than maintain two residences in tension.
What is exit taxation and does it affect me?
Exit taxation is the tax some jurisdictions impose on unrealised capital gains or accrued reserves when a tax resident , corporate or individual , leaves their tax net. Germany's Wegzugsbesteuerung is the most active example: it can deem unrealised gains on substantial shareholdings to be realised on departure. The Netherlands and France have similar regimes. Whether it affects you depends on your home jurisdiction, the size and type of your interests, and the sequencing of your departure. Coordinated planning is the difference between exposure and a clean exit.
How long does it take to obtain Romanian residence?
For non-EU citizens: a long-stay D-visa typically takes 30–60 days from application; the temporary residence permit follows within 30 days of arrival. End-to-end, plan for 60–90 days from visa application to TRP issuance. For EU citizens: registration at the local authority is a same-day or short-window process once you have the supporting documents.
Do I need a Romanian tax residency certificate?
You need it whenever a foreign tax authority requires evidence of Romanian residence , claiming treaty benefits, defending a withdrawal-of-residence claim, or supporting a permanent-establishment analysis. We obtain the certificate from ANAF, arrange any required apostille and translation, and renew it annually if your case requires.
Will I lose my Romanian residence if I travel?
Romanian tax residency requires a meaningful presence and centre-of-interests connection , not constant physical presence. Reasonable business and personal travel is compatible with residency. However, prolonged absence (typically more than 183 days outside Romania in 12 months) combined with maintained ties elsewhere is a flag. We document the residency footprint pragmatically.
Considering a move to Romania?
Tell us your origin jurisdiction, current corporate and personal position, and target timeline. We respond within one business day with a written sequencing view.
Book a 30-min scoping call