Recent content by radup

I would stay away from micro-corp for now. They recently changed the law again and they decided to put a "snake" in there. I discussed with a lawyer and he said the same thing. The law is not clearly defining the notion of consultancy or management. In RO we have these CAEN codes which are used...

Yes, I agree that 1+8% it's a lot better that 50% but things are not so simple anymore. They changed the law last year and they put a snake in the law. In order to be compliant with latest regulations to be a micro SRL you need to: - have at least one employee from day one - you are not allowed...

In that case it will be easier to ask a friend to be the owner of the LLC and eliminate the agency or even better: the LLC will be owned by two people or more. In that case the CFC rules won't apply in Romania according to PWC Romania - Corporate - Group taxation You need to own more than 50%...

We don't have the hybrid structure in Romania. It's either a corporation SRL or pass through PFA without legal protection. I am not sure 100%, but most likely any foreign entity will be treated as opaque in Romania. I am more worried about the new BEPS MLI international treaty...

There are no transfer prices in this case. This is not a multinational company. It's an US agency sub-contracting someone to do the work. As for the price, it will be the market price. This is true. The Romanian authorities might consider at some point that the US agency should hire me directly...

Yes, probably setting up the LLC to be taxed as a C Corp is a viable option. It will be taxed on profit, which won't really exist

@Marzio yes, but the US LLC is not making profit. The balance at the end of year will be zero. It will be 16% out of nothing. Am I mistaken?

Hello everyone, I am interested in creating a business setup for an IT consulting company which will target clients mostly from US. I currently live in Romania and I pay taxes there. My idea for this business setup: - Open a passthrough / single owned US LLC. No taxes payed in US as a...