VAT Refunds and Cross-Border Transactions: Disputes with ANAF for Foreign Companies

The analysis is based on the EU VAT Directive (Directive 2006/112/EC), the refund rules under Council Directive 2008/9/EC and the Thirteenth Council Directive 86/560/EEC, the Romanian Fiscal Code (Legea nr. 227/2015 privind Codul fiscal) and the Romanian Tax Procedure Code (Legea nr. 207/2015 privind Codul de procedură fiscală), as well as recent ANAF and Ministry of Finance guidance.

When Foreign Companies Must Register for VAT in Romania

Romania applies the common EU VAT system laid down in Council Directive 2006/112/EC. The Romanian rules are mainly found in Title VII of the Fiscal Code, in particular Article 268 (taxable transactions) and Article 316 (VAT registration). In practice, the key question for non-resident businesses is: when does a cross-border transaction have its place of taxation in Romania and actually require a Romanian VAT number?

Basic concepts: taxable person, taxable transaction, place of supply

Under the EU system, a taxable person is any entity that independently carries out an economic activity, regardless of legal form. VAT is due on taxable supplies of goods and services where the place of supply is in Romania, imports into Romania, intra-Community acquisitions in Romania, and certain self-supplies, as transposed into Romanian law in Article 268 of the Fiscal Code.

Article 268 of the Romanian Fiscal Code defines taxable transactions in line with the VAT Directive: supplies of goods and services for consideration, with place of supply in Romania, performed by a taxable person acting as such, as well as imports and intra-Community acquisitions of goods when Romania is the Member State of arrival. The provision mirrors the structure of Articles 2 and 31–61 of Directive 2006/112/EC.

Foreign companies and the VAT registration obligation

Article 316 of the Fiscal Code regulates VAT registration for taxable persons. Foreign companies may be:

• Non-established in Romania (no seat of economic activity and no fixed establishment in Romania), or
• Established through a fixed establishment in Romania (sufficient human and technical resources in Romania to perform taxable supplies on a regular basis).

Specialist guidance summarising Article 316 confirms that a non-established taxable person that does not apply the small-enterprise exemption must register for VAT in Romania before carrying out taxable operations where Romania is the place of supply, including certain intra-Community acquisitions and domestic supplies of goods and services.

Importantly, the domestic VAT registration threshold of 300,000 RON applies only to businesses established in Romania. Foreign companies are generally required to register as soon as they make taxable supplies in Romania and cannot rely on the small-business exemption threshold. Professional summaries of Romanian VAT law emphasise this point clearly for foreign companies.

Typical scenarios where a foreign company must register for VAT in Romania

While each transaction needs a case-by-case VAT analysis, the following situations frequently trigger a Romanian VAT registration obligation for foreign companies:

• Domestic supplies of goods located in Romania at the time of supply, where the foreign company is the supplier and Romanian reverse-charge does not apply. Typical examples include local stock sales to Romanian customers where the foreign company retains the Romanian VAT obligation.
• Installation or assembly of goods in Romania (for example industrial machinery, production lines, photovoltaic parks). Under the VAT Directive and the Romanian Fiscal Code, supplies of goods with installation are usually taxed where the installation takes place, meaning Romania in these scenarios.
• Real estate related services where the immovable property is in Romania (construction, construction-related works, leasing of business premises, certain engineering and architectural services). For such services, the place of supply is the location of the property, often creating a Romanian VAT obligation for non-residents.
• Goods imported into Romania for onward sale, where a non-resident acts as importer of record and subsequently sells the goods domestically. In these cases, the foreign company typically needs a Romanian VAT number, unless a customs and VAT simplification (such as a certain call-off stock or triangulation structure) is correctly applied.
• Intra-Community acquisitions and supplies involving Romania. A non-resident making intra-Community acquisitions in Romania or performing intra-Community supplies of goods from Romania can be obliged to register in Romania before carrying out such operations, according to Article 316 and related guidance.
• Certain B2C services to Romanian customers, particularly where the general B2B rule of Article 44 of Directive 2006/112/EC (place where the business customer is established) does not apply, or where the customer is a private individual and the place of supply is Romania (for example, some local event-related services, admission to events, short-term hiring of means of transport located in Romania).

Fixed establishment in Romania

A foreign company that has its main seat abroad may still be considered established in Romania for VAT purposes if it operates a fixed establishment in Romania with enough human and technical resources to provide supplies on a regular basis. Romanian tax law and practice follow the definition and criteria developed by the Court of Justice of the European Union and reflected in Article 11 of Council Implementing Regulation (EU) No 282/2011.

If a foreign company has such a fixed establishment, that establishment may be treated as the supplier for Romanian VAT purposes and must register for VAT in Romania under Article 316. Tax and legal commentaries on Romanian VAT stress that an entity with a fixed establishment in Romania cannot escape local VAT registration where that establishment participates in supplies.

Examples

Example 1 – German machinery supplier installing equipment in Romania: A German company sells and installs machinery in a Romanian factory. The contract covers delivery, installation and commissioning. The machinery is shipped from Germany and installed in Romania. Because this is a supply of goods with installation where the installation takes place in Romania, the transaction is taxable in Romania. Unless the Romanian customer self-accounts under the reverse-charge rules, the German supplier will generally need to register for VAT in Romania and charge Romanian VAT.

Example 2 – US company providing consultancy to Romanian VAT-registered businesses: A US consultancy provides purely advisory services to Romanian VAT-registered clients. Under the general B2B rule, the place of supply is where the customer is established (Romania). In many situations, Romanian law will apply the reverse-charge mechanism, making the Romanian customers liable for VAT and removing the obligation for the US consultancy to register locally. However, the structure must be carefully checked against current Romanian rules and any specific sectoral exceptions.

Example 3 – Online B2C supplies of services to Romanian consumers: A non-EU platform supplies digital services to Romanian individuals. EU rules generally tax such services in the Member State where the consumer is located. The platform may use special regimes (OSS or non-Union OSS) to avoid multiple local registrations, but in some structures a Romanian VAT registration may still be required, particularly if other domestic supplies are made.

VAT Refund Mechanisms for Non-Resident Businesses (Directive 2008/9/EC and 13th Directive)

Foreign companies that incur Romanian VAT without (or in addition to) being registered in Romania may be able to reclaim that VAT under special refund schemes rather than through regular VAT returns. It is essential to distinguish between three main categories:

1. Non-resident companies that are registered for VAT in Romania.
2. EU companies that are not established or registered in Romania (Directive 2008/9/EC).
3. Non-EU companies that are not established or registered in Romania (Thirteenth Directive 86/560/EEC).

1. VAT refunds for non-resident businesses registered in Romania

Once a foreign company is registered for VAT under Article 316 of the Fiscal Code, it recovers input VAT through the usual mechanism of deduction in the VAT return, not through the EU refund directives. Romanian official guidance (for example on the e-Guvernare portal) confirms that any taxable person registered under Article 316 may request reimbursement of negative VAT amounts via the periodic VAT return (Form 300), which also serves as a refund claim.

In this case, the rights and limitations on deduction (eligible expenses, partial deduction, exempt activities, etc.) derive from the general principles in Directive 2006/112/EC and their implementation in the Fiscal Code (particularly provisions transposing Articles 167–173 and 176 of the VAT Directive).

2. EU businesses: Council Directive 2008/9/EC (former 8th Directive)

For EU businesses that are not established in Romania and do not have a Romanian VAT registration, the main legal basis is Council Directive 2008/9/EC of 12 February 2008, which sets out detailed rules for the refund of VAT to taxable persons not established in the Member State of refund but established in another Member State. This Directive implements the general right to refund in Article 170 of Directive 2006/112/EC and has been applicable since 1 January 2010.

Under Directive 2008/9/EC and Romania’s implementing rules, an EU business may claim a refund of Romanian VAT if:

• It is established in another EU Member State but not established in Romania.
• It is not registered and not obliged to register for VAT in Romania during the refund period.
• The VAT was correctly charged on eligible expenses (such as participation in trade fairs, hotel and travel costs linked to business, purchase of goods and services in Romania for taxable business activities, etc.), subject to national limitations.
• It submits an electronic refund application through the VAT portal of its own Member State of establishment, which forwards the application to Romania.

Directive 2008/9/EC sets out deadlines and minimum amounts. Applications must generally be submitted by 30 September of the calendar year following the refund period. The Directive allows Member States to set minimum refund amounts (for example 400 EUR for quarterly claims or 50 EUR for annual claims), and these rules have been transposed into Romanian law. The European Commission’s VAT refunds page and the Romanian vademecum confirm these deadlines and thresholds for Romania.

ANAF has also published online guides to help businesses understand how to reclaim VAT paid in other EU countries and how Romanian entities can claim refunds abroad. While these guides focus mainly on outbound refunds, they mirror the same legal framework and give clues about how ANAF expects inbound refund claims to be documented and justified.

3. Non-EU businesses: Thirteenth Council Directive 86/560/EEC

Non-EU businesses that are not established in the EU and not registered in Romania fall under the framework of Thirteenth Council Directive 86/560/EEC, also known as the 13th Directive. This Directive harmonises the basic conditions under which Member States refund VAT to taxable persons not established in Community territory, but it leaves substantial discretion to each Member State regarding detailed conditions, exclusions and possible reciprocity requirements.

According to summaries of the 13th Directive and Romanian commentary:

• Refunds are due for VAT charged on goods and services supplied in Romania and for VAT on imports, provided those goods and services are used for the taxable activities of the non-EU business.
• Member States may impose special conditions or exclusions, for example by requiring reciprocity (that is, the non-EU country must also grant equivalent refunds to EU businesses) or by limiting refundable expense categories.
• Claims are submitted directly to the Member State of refund using its national procedure and forms, and supporting documents (often original invoices and import documents) must be attached.

Romania has historically used reciprocity declarations with certain third countries. The Ministry of Finance maintains a page with declarations of reciprocity concluded with third countries (such as Serbia, Norway, Turkey and Switzerland), clarifying under what conditions taxable persons established in those countries may obtain Romanian VAT refunds. At the same time, more recent specialised commentary states that Romania no longer generally conditions VAT refund to non-EU businesses on reciprocity and instead focuses on whether the business had an obligation to register in Romania and whether other substantive requirements are met.

Because these positions can evolve and may differ by category of expenditure and type of claimant, non-EU businesses should always verify the latest Romanian rules and, ideally, obtain confirmation from a local representative before assuming that a 13th Directive refund is available.

Example – Non-EU company attending a trade fair in Bucharest

A US company attends a trade fair in Bucharest, paying Romanian VAT on exhibition stand rental, hotel accommodation and local transport. The company is not registered for VAT in Romania and has no obligation to register there (it makes no taxable supplies with place of supply in Romania). In principle, it may claim Romanian VAT back under the 13th Directive, using the national procedure and appointing a fiscal representative in Romania, provided that the expenses are of a type for which VAT is deductible under Romanian law (for example advertising and promotional costs) and subject to any limitations or special conditions Romania may still impose.

Common Reasons Why ANAF Refuses VAT Deductions or Refunds

ANAF’s refusal of VAT deductions or refunds can be based on a mix of formal, timing and substantive grounds. Understanding the most frequent reasons helps foreign companies position their transactions and documentation from the outset to reduce the risk of denial.

1. Formal invoicing and documentation deficiencies

Even though Court of Justice case-law makes clear that the right to deduct cannot be refused solely for minor formal defects when all substantive conditions are fulfilled, in practice ANAF often invokes formal non-compliance. Typical issues include:

• Invoices missing mandatory information (such as a valid VAT identification number, a clear description of goods or services, quantity, price, VAT rate and the total VAT amount).
• Invoices issued by suppliers that appear not to be registered for VAT at the time of supply or with incorrect VAT numbers.
• Mismatches between invoices, contracts and delivery documents (for example quantities or dates that do not align).
• Insufficient supporting documents for services (for instance, consultancy billed on a lump-sum basis with no evidence of actual work, reports or deliverables).

Directive 2006/112/EC (Articles 220–226 and 178) requires the taxable person to hold a correctly issued invoice in order to exercise the right to deduct VAT. Romanian law transposes these requirements and gives ANAF a powerful formal filter for deduction claims.

2. Late or ineligible refund applications

For refund procedures under Directive 2008/9/EC and the 13th Directive, strict time limits apply. Applications must normally be submitted by 30 September of the year following the refund period for EU claimants, and national rules may set specific deadlines for 13th Directive claims. Late applications are a common reason for outright refusal, even if all substantive conditions for deduction would otherwise be met.

Other frequent eligibility issues include:

• Refund periods that are too short or too long under the applicable rules (for example, less than three months when a minimum period is imposed, or more than a year).
• Amounts below the minimum thresholds for quarterly or annual claims.
• Claimants that have, in fact, made taxable supplies in Romania that required VAT registration (making them ineligible for the refund regime and turning the case into a registration and assessment issue instead).

3. Lack of economic substance or business purpose

The Romanian Fiscal Code contains a general anti-abuse rule allowing the tax authorities to disregard or re-characterise transactions that have no real economic purpose other than obtaining a tax advantage. If ANAF considers that a structure is artificial, it may deny the related VAT deductions and refunds, sometimes even when invoices and formalities are in order.

Common patterns that raise red flags for ANAF include:

• Complex chains of intermediate suppliers with little or no apparent added value, especially in high-risk sectors such as fuel, metals, timber or electronics.
• Service agreements with affiliated or little-known entities where the services are vaguely described and not clearly linked to the beneficiary’s taxable activities.
• Transactions involving entities that lack sufficient human and technical resources to perform the billed activity.
• Unusual pricing or margin structures that suggest internal reallocation of profit rather than genuine market transactions.

In such situations, ANAF may argue that the costs lack economic substance and therefore the related VAT is not deductible, or that the overall arrangement constitutes tax avoidance or evasion.

4. Alleged VAT fraud in the supply chain (“knew or should have known” standard)

In line with CJEU case-law, especially Mahagében (Joined Cases C-80/11 and C-142/11) and Tóth (C-324/11), ANAF may deny the right to deduct input VAT where it can show that the taxable person knew, or ought to have known, that it was participating in a transaction connected with VAT fraud. The Court has emphasised that:

• The right to deduct is a fundamental element of the common VAT system, and it cannot be restricted purely because the supplier has committed irregularities.
• However, if the tax authority demonstrates, based on objective evidence, that the purchaser knew or should have known that the transaction was connected with fraud, the deduction must be refused.
• Tax authorities cannot impose disproportionate due diligence obligations on taxpayers, but businesses are expected to take reasonable steps to verify their trading partners where there are indications of risk.

Romanian practice has increasingly invoked the “knew or should have known” doctrine when denying VAT deductions in sectors with a high incidence of fraud. Foreign companies dealing with Romanian counterparties must therefore organise and document their due diligence on suppliers and customers, especially in multi-step supply chains.

5. Expenses not linked to taxable activities or blocked by law

VAT is only deductible to the extent that goods and services are used for taxable activities. Romanian law contains specific limitations on deduction for certain categories of expenditure (for example, some forms of entertainment, passenger vehicles, and certain mixed-use costs). If ANAF considers that the expenditure is not directly related to taxable operations or falls under a blocked category, it may refuse deduction or refund for the associated VAT.

For foreign companies, this can be surprising when incurring “general business” costs (such as hotels, meals, corporate events or marketing campaigns) in Romania. The key is to understand in advance which types of costs are deductible under Romanian rules and to collect documentation that clearly shows the link with future taxable supplies.

How to Challenge VAT Decisions and Prove the Substance of Transactions

If ANAF denies a VAT refund or input VAT deduction – whether via a formal decision on a refund claim or through a tax inspection and additional assessment – the foreign company usually has two levels of recourse:

1. An administrative appeal (contestație) before ANAF’s specialised structures and the Ministry of Finance.
2. A subsequent judicial challenge before the Romanian administrative courts.

Administrative appeal: strict deadlines and detailed arguments

Under the Romanian Tax Procedure Code, contestations against tax administrative acts (including VAT assessment decisions and refund refusals) must generally be filed within 45 days from the date of communication of the decision. The Ministry of Finance and ANAF confirm this deadline in official guidance. If the act does not clearly mention the right to contest or the relevant deadline and authority, a longer three-month term may apply, but foreign companies should not rely on this exception without legal advice.

The administrative appeal should:

• Identify precisely the contested act (for example, the VAT assessment decision number and date, or the decision rejecting the refund claim).
• State the amounts and issues being contested (for example disallowed input VAT, refused refund amount, penalties and interest).
• Present legal arguments (references to the Fiscal Code, EU VAT Directive and relevant CJEU case-law) explaining why the deduction or refund should be granted.
• Attach supporting documentation to prove the reality of transactions, the connection with taxable outputs and the absence of abuse or fraud.

For disputes involving cross-border transactions, it is critical to show how the Romanian rules must be interpreted in light of Directive 2006/112/EC and CJEU jurisprudence, particularly regarding the primacy of substance over form, the conditions for deduction, and the limits on anti-abuse measures.

Judicial review: enforcing EU-law-consistent interpretation

If the administrative appeal is rejected or only partially accepted, the taxpayer may bring an action before the competent Romanian administrative court. The court will review the legality of the ANAF decision, taking into account Romanian law, EU law and the evidence presented. For foreign companies, judicial proceedings often provide a more neutral forum to enforce EU-law-consistent interpretations, particularly in complex VAT fraud or abuse cases.

While litigation can take years, statistics show that a significant portion of disputes lost at the administrative stage are at least partially corrected by courts, especially where ANAF has been overly formalistic or has incorrectly applied the “knew or should have known” standard without sufficient proof.

Proving the substance of transactions: what ANAF and the courts expect

Regardless of the forum, the central battle in VAT disputes with ANAF is often about substance: were the transactions real, and were the goods or services actually used for the claimant’s taxable economic activity?

Key types of evidence include:

• Contracts and addenda clearly identifying the parties, scope of services or goods, pricing and payment terms, delivery terms (Incoterms), responsibilities for VAT and statutory obligations.
• Order forms, offers and acceptances, showing that the transaction was negotiated and agreed under business-like conditions.
• Delivery documents such as CMRs, delivery notes, warehouse records, transport orders, proof of loading/unloading, and inventory records for goods.
• Service performance documentation such as timesheets, progress reports, meeting minutes, deliverables, attendances at workshops or training sessions, and final acceptance certificates.
• Bank statements and payment evidence demonstrating that the consideration and VAT were actually paid on normal commercial terms.
• Internal communications and business justification (emails, investment proposals, budgets, board decisions) showing why the goods or services were acquired and how they support the company’s taxable activities.
• Due diligence on counterparties, including trade register extracts, VAT registration confirmations, financial statements or credit reports, and internal risk assessments, especially in high-risk sectors.

The more coherent and contemporaneous this set of evidence is, the stronger the case that the transactions are genuine and free of abusive intent, making it harder for ANAF to sustain a denial based only on supplier misconduct or minor formal issues.

Using EU case-law strategically

EU case-law is a powerful tool in disputes with ANAF, since Romanian courts and authorities must interpret domestic law in compliance with EU law. In the VAT context, important principles include:

• The right to deduct is a fundamental principle of the common VAT system and may not be limited in a way that undermines VAT neutrality.
• Deduction cannot be refused solely because of formal errors if the substantive conditions are fulfilled and the tax authority has all the information necessary to confirm this.
• However, deduction must be refused if the taxable person knew, or ought to have known, that the transaction was connected with fraud.
• National anti-abuse rules must be proportionate and cannot create a presumption of fraud without objective evidence.

Foreign companies should frame their appeals and court submissions explicitly in terms of these principles, citing relevant CJEU decisions where necessary and showing how their facts fit within the protective scope of EU law rather than within a pattern of fraud or abuse.

Practical Tips on Documentation and Contracts

The best VAT disputes are those that never start. For foreign companies trading with Romania, careful structuring of contracts, flows and documentation significantly reduces the risk of confrontation with ANAF and increases the chances of success if a dispute nonetheless arises.

1. Plan the VAT treatment before signing the contract

Before entering into a new Romanian-related structure, ask at least the following questions:

• Where is the place of supply under the VAT rules (for each element of the transaction: goods, services, installation, transport, insurance, etc.)?
• Who is the person liable for VAT (supplier, customer, or both under a reverse-charge or joint liability rule)?
• Does the foreign company need to register for VAT in Romania, or can the structure rely on OSS/IOSS regimes, reverse charge mechanisms or other simplifications?
• What is the chain of invoices and how will each invoice reflect the reality of supplies and movements of goods?
• Are there any sector-specific VAT rules (for example for real estate, telecoms, digital services, travel, energy, waste, or second-hand goods) that modify the general approach?

Once the intended VAT treatment is clear, it should be reflected in the contract (for example via clauses indicating whether prices are VAT-exclusive or VAT-inclusive, which party bears the risk of VAT reclassification, and who undertakes to comply with local registration and reporting obligations).

2. Draft contracts with VAT and substance in mind

Contracts should not only reflect commercial reality but also help demonstrate it to ANAF. Some practical drafting points include:

• Clear description of goods and services, including scope, deliverables, milestones, and measurable outputs.
• Precise delivery terms (Incoterms and locations) for goods, so that the flow of goods can be matched with transport and customs documents and the place of supply can be explained.
• Transparent pricing structure showing how consideration is calculated (for example day-rates, per-unit prices, margins) and why the agreed prices make commercial sense.
• Allocation of VAT responsibilities, including who must register where, who will issue which invoices, and what happens if the tax treatment is challenged.
• Audit and information clauses permitting the parties to obtain the documents necessary to prove the reality and purpose of the supplies, including in the context of tax audits.
• Anti-fraud and compliance clauses requiring each party to comply with tax obligations and giving the other party a right to terminate if significant tax irregularities are discovered.

Well-drafted contracts are not enough on their own, but in disputes they provide a strong starting point to show that the structure was conceived as a genuine business operation, not a tax-driven façade.

3. Build a robust documentation trail

For both VAT registration and refund purposes, foreign companies should build and maintain a documentation system that ANAF and courts can follow without guesswork. Good practice includes:

• Maintaining a deal file with the contract, annexes, correspondence, approvals and internal analyses for each major transaction.
• Centralising invoices and credit notes together with proof of delivery or performance.
• Using consistent document numbering and references so that contracts, orders, invoices and logistics records can be easily cross-checked.
• Retaining evidence of use of goods and services in taxable activities (for example integration of equipment into production lines, marketing campaigns, use of consultancy in strategy implementation).
• Keeping records of VAT return positions and refund claims, including the specific invoices and transactions included in each claim.

For refund claims under Directive 2008/9/EC or the 13th Directive, ensure that the descriptions, codes and classifications requested in the electronic or paper forms are filled in accurately and consistently with the invoices and Romanian categories of deductible expenses.

4. Strengthen due diligence on Romanian counterparties

To mitigate the risk that ANAF will later allege that you “knew or should have known” about a supplier’s fraud, foreign companies should document their due diligence process. Steps typically include:

• Checking the supplier’s registration in Romanian trade registers and VAT registers before starting the relationship.
• Reviewing financial information or credible credit reports where appropriate.
• Verifying that the supplier has the human and technical capacity to perform the services or deliver the goods offered.
• Monitoring unusual changes in behaviour (for example sudden price decreases, frequent changes of bank accounts, refusal to provide supporting documents).
• Documenting the checks performed and any red flags and responses.

These measures do not guarantee that ANAF will not challenge your deductibility, but they provide strong evidence that you acted with reasonable care and did not participate knowingly in any fraudulent scheme.

5. Coordinate local representation and communication with ANAF

For non-resident businesses, especially non-EU entities, appointing a local fiscal representative or VAT agent in Romania is often mandatory for refund procedures and highly advisable for registration and compliance. A representative familiar with Romanian practice can:

• Help choose the most efficient structure (local registration, OSS/IOSS, 13th Directive refund, etc.).
• Prepare and submit refund claims and VAT returns correctly and on time.
• Handle ANAF queries during desk reviews and tax inspections in Romanian, reducing the risk of misunderstandings.
• Assist in building the factual and legal case in administrative appeals and litigation.

Effective communication with ANAF, including timely and clear responses to requests for clarification, often makes the difference between a manageable adjustment and a protracted dispute.

Sources and Further Reading

Below is a non-exhaustive list of key primary and secondary sources relevant for Romanian and EU VAT on cross-border transactions and refunds:

• Council Directive 2006/112/EC on the common system of value added tax (consolidated text)
• Council Directive 2008/9/EC – refund of VAT to taxable persons not established in the Member State of refund but established in another Member State
• Thirteenth Council Directive 86/560/EEC – VAT refunds to taxable persons not established in Community territory
• CJEU, Joined Cases C-80/11 and C-142/11, Mahagében and Dávid and Case C-324/11, Tóth
• Legea nr. 227/2015 privind Codul fiscal (Romanian Fiscal Code) and related implementing norms
• Legea nr. 207/2015 privind Codul de procedură fiscală (Romanian Tax Procedure Code), including provisions on contestations
• European Commission – VAT refunds information (including references to Directives 2008/9/EC and 86/560/EEC)
• Romanian e-Guvernare portal – VAT refunds
• Ministry of Finance – declarations of reciprocity with third countries for VAT refunds
• Recent Romanian and international tax commentaries on VAT registration, fixed establishments, the use of special regimes (OSS/IOSS) and the practice of ANAF and Romanian courts in VAT disputes.