Open a Romanian company from the UK — €990 flat.

The UK–Romania double tax treaty

Since Brexit the UK is outside the EU, so the EU directives that reduce withholding between member states no longer apply to a UK founder — the UK–Romania treaty is what governs cross-border payments. It caps Romanian withholding on money leaving the SRL and lets you credit Romanian tax against UK tax on the same income.

The dividend rate depends on the recipient and ownership level (the lower rates favour qualifying corporate holdings; an individual shareholder typically sits higher). Because the UK is no longer an EU state, the EU Parent-Subsidiary and Interest & Royalties Directives are not available — the treaty caps above are what you rely on. Rates per the UK–Romania treaty as summarised by PwC; confirm eligibility for your case.

Permanent establishment & central management and control

The treaty taxes the SRL in Romania unless it has a permanent establishment in the UK. The residence trap is separate: a company is UK-resident if it is incorporated in the UK or its central management and control (CMC) is exercised in the UK. So a Romanian SRL whose board-level decisions are really taken from London can be treated as UK tax-resident and taxed on its worldwide profit, with the treaty tie-breaker pointing to the place of effective management. Keeping genuine management and substance in Romania — office, local decision-making, an employee — is what keeps CMC out of the UK.

UK anti-avoidance — CFC and Transfer of Assets Abroad

Two UK regimes are relevant. The UK's controlled-foreign-company rules (Part 9A of TIOPA 2010) mainly bite where a UK company owns the foreign subsidiary, attributing certain profits back to the UK parent — so they matter if you hold the SRL through a UK Ltd rather than personally. For a personally owned SRL, the rule to know is the Transfer of Assets Abroad code (ITA 2007), a broad anti-avoidance regime that can tax a UK-resident individual on income of an overseas company they have provided value to, where a tax-avoidance purpose is present and no genuine commercial defence applies. Running a real trading business with substance, not a profit-parking shell, is the distinction that matters. Because the micro-company regime is a low turnover tax, take UK advice on how these rules read against your setup.

On the reporting side, a UK-resident owner declares dividends and any other income from the SRL through Self Assessment — the foreign income pages (SA106) are the usual route where foreign tax has been withheld and a credit is claimed. VAT is now two separate systems: your Romanian SRL registers for EU VAT and can use the EU One-Stop-Shop for B2C sales into the EU, entirely apart from any UK VAT registration a UK Ltd of yours might hold.

Who opens a Romanian SRL from the UK

Post-Brexit, mostly UK founders who need an EU-resident company for EU VAT, EU marketplaces and EU clients that now treat a UK Ltd as a non-EU supplier — freelancers, agencies, e-commerce and SaaS founders. Many keep the UK Ltd and add the SRL as their EU arm. See how formation works and Romanian accounting.

This page is general information for UK founders, not UK tax advice. Your CFC/ToAA exposure, corporate-residence position and VAT depend on your own facts — confirm them with a UK adviser.