Karolina Nowak

BDO Czech Republic is excited to announce the opening of a new office in Pardubice, East Bohemia. The office will be led by Jindrich Novak, who knows the region and its business environment well. In the new office, the team will provide accounting and payroll outsourcing (BSO) services, as well as tax consulting, with plans to expand into audit and advisory. The new office marks their 9th office, strengthening their ability to support clients within their own region.

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VAT subsidiary establishments - KPMG in Romania Tax & Legal secures a decisive VAT court success Led by Alin Negrescu, Head of Indirect Tax, our team secured a definitive Supreme Court ruling annulling a tax authority decision that had wrongly claimed a non-resident company had a Romanian fixed establishment via its subsidiary. By leveraging CJEU jurisprudence, we successfully defended the VAT-free treatment of processing services, overturning significant additional VAT assessments. #kpmg #clearchoice CC: Alin Negrescu, Georgiana Enache, Andrei Tudor

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Romania introduces important updates to transfer pricing 👇 Romania is taking concrete steps to enhance transparency and efficiency in its transfer pricing framework. Recent legislative changes, effective July 2025, bring new requirements and greater clarity for international companies operating in Romania. 📌 What’s changing? • 𝐀𝐝𝐯𝐚𝐧𝐜𝐞 𝐏𝐫𝐢𝐜𝐢𝐧𝐠 𝐀𝐠𝐫𝐞𝐞𝐦𝐞𝐧𝐭𝐬 (𝐀𝐏𝐀𝐬): The process for obtaining APAs is now more streamlined. Companies can expect clearer procedures and shorter timelines. A roll-back period of up to five years also improves the business case for wanting to obtain an APA. The APA can also be used to resolve an audit. • 𝐃𝐨𝐜𝐮𝐦𝐞𝐧𝐭𝐚𝐭𝐢𝐨𝐧 𝐫𝐞𝐪𝐮𝐢𝐫𝐞𝐦𝐞𝐧𝐭𝐬: The threshold for mandatory transfer pricing documentation is reduced, so more businesses will need to comply. Updated guidance helps remove uncertainty. • 𝐒𝐭𝐫𝐨𝐧𝐠𝐞𝐫 𝐜𝐨𝐨𝐩𝐞𝐫𝐚𝐭𝐢𝐨𝐧: Romanian tax authorities aim to increase dialogue and support early resolution of potential disputes. 👉 Why does this matter? Romania is known to be difficult in accepting HQ-charges, royalties and access to MAP-procedures. These changes may provide new opportunities to resolve such issues. 💡 Want to stay ahead of these changes? Follow me and explore our newsletter, webinars, and podcasts by clicking ‘Visit my website’ below my name.

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What if Aristotle were an auditor? 🧐   In this thought-provoking article, Lluís E. Guerra Vidiella from PrimeGlobal member firm AUDITIA Audit, Tax and Advisory explores how Aristotle’s timeless wisdom from Nicomachean Ethics could reshape the way we think about auditing.   As regulations tighten, auditors need more than checklists — they need judgment, integrity, and responsibility to truly restore trust in the profession. A powerful reminder that ethics go beyond rules. 🔗 Link to the full article in the comments.   #PrimeGlobal #Audit #Ethics #ProfessionalJudgment #Leadership #FutureOfAudit

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VAT & Transfer Pricing Adjustments: ECJ/CJEU issued the decision in the case C-726/23 (Arcomet Towercranes) – Transfer Pricing Adjustment for intra-group services subject to VAT; documentation required Preliminary Ruling Context: The case involves SC Arcomet Towercranes SRL and Romanian tax authorities regarding the application of VAT on services provided within a corporate group. The primary legal questions concern the interpretation of the VAT Directive regarding intra-group service remuneration and the right to deduct VAT. Interpretation of VAT Directive: The Court ruled that remuneration for services provided by a parent company to its subsidiary, determined by OECD transfer pricing principles and linked to operating margins, constitutes “consideration” for services under Article 2(1)(c) of the VAT Directive, thereby falling within the scope of VAT. Deduction of Input VAT: The Court clarified that tax authorities can require documentation beyond just invoices to prove the existence and usage of services for taxable transactions, in line with Articles 168 and 178 of the VAT Directive. This is permissible as long as the additional documentation requirement is deemed necessary and proportionate. Legal Relationship & Economic Reality: The ruling emphasized the importance of a direct link between the services provided and the remuneration received, affirming that the economic and commercial realities of the transaction must be considered to ascertain if a service was rendered for consideration. Implications for Tax Practice: The decision highlights the need for companies to maintain thorough documentation of intra-group transactions to substantiate VAT deductions and the necessity for tax authorities to assess both formal and substantive conditions when evaluating VAT claims. https://lnkd.in/eDUNuJus

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𝗗𝗼𝗶𝗻𝗴 𝗕𝘂𝘀𝗶𝗻𝗲𝘀𝘀 𝗼𝗻 𝘁𝗵𝗲 𝗨𝗸𝗿𝗮𝗶𝗻𝗶𝗮𝗻 𝗙𝗿𝗼𝗻𝘁𝗹𝗶𝗻𝗲 – was the name of the event where I had the honor to speak. It was co-organized by BDO in Ukraine and European Business Association and other partners in Rome 🇮🇹 earlier in June during #URC25. Here are a few key updates from the last three months: • Russian attacks have become even more brutal. Just today, a tragic record was set – 805 drones and missiles were launched against 🇺🇦 in one night. But at the same time: • 238 frontline municipalities received permission to retain 100% of employees from military service – ensuring greater workforce stability and making businesses in these territories more attractive employers. • The governmental loan program 5-7-9% is now 1% for the first five years for businesses in frontline regions – providing financial stability and opportunities for growth. • For the processing industry, in cases of destruction of production facilities or other assets, a cash compensation program is in place. • A war risk insurance draft law is under consideration in Parliament; private boutique solutions already exist, while DFC insurance is available for large projects. • The new PPP law has been passed and will be fully operational soon. • Public Investment Management Reform is advancing rapidly, with 260+ priority projects already identified. • More donors and foreign states are committing to concrete recovery projects. • The 🇺🇸–🇺🇦 “mineral deal” has officially started operating. • Administrative fees and state duties for business and property registration have been cancelled. • Agricultural support: • a 1,000 UAH per hectare subsidy for farmers in combat zones; • grants up to 400,000 UAH per hectare for orchards and greenhouses, covering up to 80% of expenses. And much more is on the way. To conclude: even under relentless attacks, Ukraine is implementing reforms that remove barriers, de-risk investments, and provide direct support to businesses, farmers, and communities. This is more than survival – it is the creation of a new model of economic governance under extreme conditions, where business, state, and international partners act in sync. Ukraine is not just rebuilding; it is 𝗱𝗲𝘀𝗶𝗴𝗻𝗶𝗻𝗴 𝗴𝗹𝗼𝗯𝗮𝗹 𝘁𝗲𝗺𝗽𝗹𝗮𝘁𝗲𝘀 𝗳𝗼𝗿 𝗿𝗲𝗰𝗼𝘃𝗲𝗿𝘆, 𝗶𝗻𝘃𝗲𝘀𝘁𝗺𝗲𝗻𝘁, 𝗮𝗻𝗱 𝗴𝗿𝗼𝘄𝘁𝗵 𝗶𝗻 𝗵𝗶𝗴𝗵-𝗿𝗶𝘀𝗸, 𝗵𝗶𝗴𝗵-𝗼𝗽𝗽𝗼𝗿𝘁𝘂𝗻𝗶𝘁𝘆 𝗿𝗲𝗴𝗶𝗼𝗻𝘀. 🔗 More details: https://lnkd.in/d5H8mXTq

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