A German-owned company registered in Romania lives in two accounting worlds at once. On one side, it must fully comply with Romanian tax and accounting law: the Fiscal Code, the accounting regulations under OMFP 1802/2014, filings with the tax authority ANAF, e-Factura and SAF-T. On the other side, it is part of a German group that reports under different rules, in a different language and often in a different currency. Keeping the books correctly in Romania is not enough; the information has to reach the parent company in a form it can consolidate and understand.
This dual requirement is exactly where an accounting firm focused only on the local market runs into trouble. It is not simply a matter of translation. It is about understanding what a Kontenrahmen is, how a Romanian account maps onto the group chart of accounts, what differences arise between HGB and Romanian rules on depreciation or provisions, and how to document intra-group transactions so they hold up both in an ANAF audit and in the group audit.
In this article we explain the concrete needs of German companies in Romania and how a Steuerberatung approach — German-style tax advisory applied on Romanian ground — reduces risk, time and friction with the parent company.
The specific needs of German-owned companies
Subsidiaries and companies held by German investors have a different needs profile than a classic Romanian company. In practice, the most frequent requirements are:
- Fluent communication in German with the CFO or the group accounting department, including explaining Romanian tax specifics in language they understand.
- Monthly reporting in the group format, often in euro and on the parent company’s account structure, not just the Romanian trial balance.
- Mapping the chart of accounts from Romanian to the group’s Kontenrahmen (usually SKR03 or SKR04).
- Managing intra-group transactions: loans from the parent, services, transfer pricing, royalties.
- Correct application of the double taxation treaty between Romania and Germany on dividends, interest and royalties.
- Predictability and punctuality: group reporting deadlines are often stricter than Romanian tax deadlines.
These needs are not covered by simple invoice entry. They require a partner who understands both systems. See our full range on the services page.
Communicating in German with the parent company
The most common source of frustration for a German group is not the figure itself, but the inability to get a clear explanation. When the Romanian manager and the local accountant speak only Romanian, and nobody in Frankfurt or Munich understands why an expense was treated a certain way, delays, extra checks and mistrust follow.
An accountant who communicates directly in German with the Muttergesellschaft removes this translation layer. They can answer questions about VAT, deductibility, the treatment of a provision, or the reason for a difference between local and group reporting — in the language and logic the German partner uses. The result is a faster month-end close and a climate of trust between subsidiary and group.
Group reporting: format, currency and mapping
Romanian accounting must be kept in lei and on the national chart of accounts. The German group, however, needs the data in its own structure, usually expressed in euro for consolidation. The gap is not closed mechanically by a currency conversion. It involves a series of technical decisions:
- Account mapping: each account in the Romanian trial balance is linked to an account in the group’s Kontenrahmen. A depreciation charge, for example, must land in the correct group account, not in a generic position.
- Currency translation: balance sheet positions are usually translated at the closing rate and profit and loss items at an average rate; currency differences are isolated separately, according to group policy.
- Reclassifications: some positions treated one way in Romania must be reclassified to match HGB presentation or group policy.
- Reporting package: delivery to the group follows a fixed calendar and format, often with explanatory notes.
A well-built mapping at the outset saves dozens of hours every month and reduces the risk of consolidation errors. It is an investment that pays off quickly.
HGB vs. Romanian accounting: where the differences arise
Although both systems come from the continental European accounting tradition and share much common ground, there are differences between HGB (Handelsgesetzbuch, the German Commercial Code) and Romanian accounting rules that directly affect the reported figures. The table below summarises the most relevant ones:
| Aspect | Romanian accounting (OMFP 1802/2014) | HGB (Germany) |
|---|---|---|
| Guiding principle | True and fair view, with strong tax influence | Marked prudence principle (Vorsichtsprinzip), creditor protection |
| Depreciation | Useful lives and methods often aligned with tax rules | Economic useful life; possible divergence from the tax treatment |
| Provisions | Recognised under relatively strict conditions | Broader recognition of provisions for risks and obligations |
| Inventory valuation | FIFO or weighted average cost | FIFO, LIFO permitted under certain conditions, lower-of-cost principle |
| Documentation | Supporting document required for every operation | Belegprinzip, similar, with its own practices |
| Reporting currency | Lei (RON) | Euro |
These differences do not mean a subsidiary keeps two complete, parallel sets of books. The statutory accounting remains the Romanian one; the adjustments toward HGB are made in the reporting package through a set of controlled reclassifications and corrections. What matters is that these adjustments are documented and repeatable, not improvised each month.
Double taxation: the Romania–Germany treaty
Financial flows between the Romanian subsidiary and the German group — dividends, interest on intra-group loans, royalties for licences or trademarks — can be taxed in both states if the available instruments are not applied correctly. Two layers of protection come into play here:
- The double taxation treaty between Romania and Germany, which sets reduced withholding tax rates and the method for eliminating double taxation.
- The EU directives (for example the parent-subsidiary regime for dividends and the interest and royalties directive), which, under certain holding and duration conditions, can reduce withholding tax to zero.
To benefit from these advantages, the subsidiary needs the correct documentation: a tax residence certificate for the German recipient, compliance with the holding conditions and, where necessary, the transfer pricing file. Withholding rates and conditions can change, so the value in force must be checked at the time of payment. Incorrect application means either tax paid in excess and non-recoverable, or a risk of penalties in an ANAF audit.
Digital obligations: e-Factura, SAF-T and e-Transport
Regardless of the German angle, every company in Romania must comply with the digital reporting framework, which has expanded significantly in recent years. For a German subsidiary, these obligations must also be explained to the group, because they affect flows and systems:
- e-Factura (RO e-Factura): electronic invoicing through the national system is mandatory in B2B relations; invoices are sent and received through the ANAF platform.
- SAF-T (the D406 return): standardised reporting of accounting data to ANAF, at a high level of detail.
- e-Transport: monitoring of goods transports, particularly relevant for companies with cross-border goods flows.
Integrating these obligations with the group’s ERP system (for example SAP or DATEV) requires planning. We can help you connect Romanian requirements with the group infrastructure — see how we help.
Why Conta Fiscal for German companies
Conta Fiscal (Contafiscal Steuerberatung) has been a member of the Romanian body of chartered accountants CECCAR since 2004, with over 20 years of experience, and works consistently with foreign-owned companies. We are members of the AHK (German-Romanian Chamber of Commerce) and treat the German company segment as a specialisation, not an exception. We communicate directly in German with the parent company, deliver reporting in the group format and handle double taxation and intra-group transactions correctly.
If you manage a German subsidiary in Romania or plan to open one, talk to us about your group’s concrete needs. Contact us for an initial assessment and a reporting plan tailored to you.
Frequently asked questions
Do I have to keep two sets of books, a Romanian one and a German one?
No. The statutory accounting stays Romanian, in lei. Group reporting is derived from it through account mapping, currency translation and a set of controlled reclassifications, delivered as a reporting package.
Can you communicate directly in German with the parent company?
Yes. We communicate fluently in German with the CFO or the group accounting department and explain Romanian tax specifics in the language and logic the German partner uses.
What is chart-of-accounts mapping?
How does my company avoid double taxation on dividends or interest?
By applying the Romania–Germany treaty and, where applicable, the EU directives. A tax residence certificate and compliance with the holding conditions are required; the rates in force are checked at the time of payment.
What are the main differences between HGB and Romanian accounting?
The treatment of provisions and depreciation differs, the prudence principle is more marked in HGB, and inventory valuation and the reporting currency (euro vs. lei) differ. Adjustments are made in the reporting package.
Are you an AHK member?
Yes, Conta Fiscal is a member of the German-Romanian Chamber of Commerce (AHK) and regularly serves German subsidiaries and investors in Romania.