Kinstellar is pleased to announce that it has advised Special Flanges, a leading Italian manufacturer of high-performance forged components, on the acquisition of 100% of the shares in Vilmar, a Romanian industrial company with over 50 years of experience in the production of engineered equipment for critical applications. The transaction marks Special Flanges’ first direct investment in Romania and represents a key milestone in the group’s strategic expansion across Central and Eastern Europe. The acquisition was carried out by the Wise Equity V fund managed by Wise Equity SGR – through its subsidiary Special Flanges – and involved the transfer of Vilmar from the French group Genoyer. The integration will create
Ukrainian taxpayers operating within multinational enterprise groups (MNEs) with consolidated annual revenues exceeding EUR 750 million may, for the first time in 2025, be required to independently file Country-by-Country (CbC) reports. This applies in particular to companies that are part of MNEs with a U.S.-based ultimate parent entity. Please read the complete overview below in English or in Ukrainian. Download in English: Download in Ukrainian:
At Kinstellar, we understand that tax audits and disputes can pose significant challenges to businesses. To better serve our clients in this critical area, we have brought together our tax advisory and litigation teams into a dedicated Tax Disputes & Audit Task Force. This newly established task force combines the full strength of our tax and legal expertise to support companies facing the risk—or the reality—of a tax inspection or fiscal litigation. Our professionals work hand-in-hand to help you anticipate risks, prepare your teams, manage the audit process, and defend your case with confidence in all procedural phases. Whether you're seeking to avoid future exposure, handle an ongoing audit, or resolve
On 2 May 2025, the Austrian Ministry of Finance published a draft bill of the Budget Accompanying Act proposing significant amendments to the Austrian Real Estate Transfer Tax Act with potential far-reaching implications for M&A transactions. The proposed changes to the Real Estate Transfer Tax Act would tighten the tax treatment of so-called “share deals”—transactions where shares in corporations or partnerships owning real estate are transferred instead of the real estate itself. These changes, aligned with the Austrian government’s 2025–2029 program, aim to close any existing loopholes that have enabled the avoidance of real estate transfer tax in real estate transactions. Reduction of the ownership
Historically, customs duties are considered to be the origin of taxation. Today, looking specifically at the current U.S. administration, customs duties—better known as tariffs—are primarily used as tools of trade policy. Rising customs duties are creating uncertainties for multinational companies and supply chains. With the ongoing increases in customs duties, the question arises: How can multinational companies adequately address new tariff regulations from the tax law perspective? Customs valuation review Rising customs duties can significantly impact the cost structure of imported/exported goods and, thus, disrupt carefully planned transfer pricing arrangements and related intercompany agreements between
As described in our previous newsletter in September 2024, profit taxpayers and microenterprise income tax taxpayers in Romania benefit from a 3% discount of their annual profit/income tax liability related to fiscal year 2024/the modified fiscal year starting in 2024. The procedure for applying the aforementioned discount was approved by Order 540/2025 published on 14 April 2025. To benefit from this discount, taxpayers need to fulfil the following conditions: they must have all mandatory tax returns submitted in due time; the annual profit/income tax related to fiscal year 2024/the modified fiscal year starting in 2024, as the case may be, is paid in full within the applicable legal deadlines;
Kinstellar is delighted to announce that Maja Mayrhuber, a reputable tax lawyer, has joined our newly launched Vienna office as a Partner. Maja’s arrival marks an important step in building our tax capabilities in Austria and driving the growth of this service line across the wider C/SEE region. Maja Mayrhuber specialises in national and international tax law, with a focus on corporate taxation, tax planning, and tax advice related to international restructurings, M&A, corporate finance, and real estate transactions. Maja regularly advises both international companies and private clients on a broad spectrum of tax issues, including VAT, tax audits, transfer pricing, and fiscal criminal law. She also represents clients
On 4 April 2025, Romania government Emergency Ordinance no. 21/2025 ("the GEO") was published and entered into force, introducing several important amendments and clarifications regarding the recently enacted construction tax. We summarise the main provisions below. Reduction of the tax rate: The construction tax rate has been decreased from 1% to 0.5%. Tax base clarification: It is now explicitly clarified that the 0.5% tax applies to the net book value of constructions. New separate tax (0.25%): A separate tax of 0.25% has been introduced for buildings belonging to the public or private domains of state or administrative-territorial units that are utilised based on contracts, agreements, or legal
It has become standard practice in Hungary for solar power plants to be developed on greenfield agricultural land owned by third parties. Due to legal restrictions regarding the use of agricultural land, developers are unable to acquire these plots until the project is completed. Unlawful taxation practice challenged Recently, the National Tax and Customs Authority (the “Tax Authority”) calculated the transfer duty not only based on the market value of the underlying land but also included the market value of the solar park entirely constructed by the developer, which resulted in exorbitant tax burdens. The Hungarian Supreme Court (the “Kúria”) recently ruled against the Tax Authority regarding
Ukraine has introduced two important laws to strengthen the fight against corruption. The laws—No. 4111-IX (Draft Law No. 11443) and No. 4112-IX (Draft Law No. 10319)—passed by the Ukrainian parliament on 4 December 2024, introduce stricter penalties for corruption, including criminal liability for companies and tax consequences for unethical practices. The new measures include heavier fines, property confiscation, and stricter tax rules to combat bribery and financial crimes. Click on one of the images below or use the following links to read our overview in English or in Ukrainian. Download in English: Download in Ukrainian:
On 30 December 2024, the Romanian government adopted Emergency Ordinance no. 156/2024 (“the GEO”) regulating a series of important fiscal changes that entered into force starting January 2025, as summarised below. 1. Increase of dividend tax from 8% to 10% for all taxpayers obtaining income from dividends, i.e., companies, individuals, and non-residents. The increased tax applies to dividends distributed starting with 1 January 2025. 2. Elimination of tax incentives, i.e., exemption from income tax, reduced pension insurance contribution, for salary income lower than RON 10,000 earned by individuals carrying out activity in IT, construction, agricultural and the food industry. For these sectors, regular (full)
The Corporate Sustainability Reporting Directive (EU) 2022/2464 (the “CSRD”) required EU member states to complete its transposition by 6 July 2024. However, uneven implementation led the EU Commission to initiate infringement proceedings against 17 member states, including the Czech Republic and Romania, on 26 September 2024, citing their failure to fully communicate the necessary transposition measures. These states now face a two-month deadline to finalise the process and respond to the formal notice. While the CSRD’s transposition is nearing completion, attention is turning to the Corporate Sustainability Due Diligence Directive (EU) 2024/1760 (the “CSDDD”), an equally significant piece of legislation.