Recent initiatives of the Romanian National Agency for Fiscal Administration (the "NAFA") - including on site controls - showcase the Agency's interest in verifying the VAT and PE structures set-up and deployed for business purposes by the international companies active in the pharmaceuticals sector in Romania.

Based on publicly available information, the focus is on the evaluation of any potential source of fraudulent behaviour, particularly concerning the avoidance of payment of due VAT (for example, by the miss-qualification of certain activities in the field of marketing, promotion and authorisation of parent-companies).

It is important to note that, in the cases where NAFA identifies an instance of potential misconduct, criminal procedures are initiated and recovery of damages is sought.