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Healthcare & pharma

Use case · Tax

Pharma clawback and sales-based levies: a CFO note on what the company owes

Reimbursed medicines sold in Romania and Spain each carry a levy on industry. Research the rules in force for each period and draft a cited note for the CFO.

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CFO in a charcoal suit jacket holding a printed summary over a boardroom table with closed binders

This task, run in azta

azta
We hold the marketing authorisations for nine reimbursed medicines sold in Romania and Spain through local distributors.
RO · ES
Researching

Searching legislatie.just.ro

Searching ANAF

Searching BOE

Searching EUR-Lex · Curia

Two different mechanisms. Romania applies a clawback that links industry payments to public spending on reimbursed medicines. Spain requires contributions based on sales of medicines financed by its national health system. They share a purpose but differ in base, period and payer, so each needs its own analysis.
Read the version in force for each period. Both regimes are set by national legislation that can be amended. The amount for each quarter follows the rules in force for that quarter, so the note should cite the version that applied, not only today’s text.
Who is liable is its own question. National law names the person who pays. Where a marketing authorisation holder sells through a local distributor or representative, the research has to establish which of them the law makes liable, and the contracts show who bears it commercially.
Tax treatment is a separate question. Whether the levy is deductible for corporate income tax, and how it is shown in the accounts, is not answered by the levy law itself. The note should cover it separately, with its own sources.
Draft the cfo note
pharma-clawback-levy.docx
Regenerate
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Word (.docx)PDF
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Levies on reimbursed medicines: Romania and Spain, 2026

Romania. Our reading of the rules cited in the table is that the company, as marketing authorisation holder, is the liable person for its reimbursed products. The distributor agreements should be checked for any contractual pass-through. The amount for each quarter follows the version of the rules in force for that quarter.

Spain. The contribution is calculated on sales of the products financed by the national health system. The table sets out the base, the percentage and the payment schedule as stated in the provisions cited, for each product sold there.

Open points. Whether the levies are deductible for corporate income tax in each country, and whether the Romanian amount for the second quarter needs correcting, are listed for the tax team with the questions to settle.

Sources · legislatie.just.ro · ANAF · BOE · EUR-Lex · Curia
Saved

A replay of this page’s example. In azta every line of the answer carries a citation that opens the provision itself.

The situation

Reimbursed medicine sales in Romania and Spain, by product and quarter

Your company holds the marketing authorisations for nine reimbursed medicines sold in Romania and Spain. The budget review is in three weeks and the board wants one page: which levies the company pays on publicly funded sales, how each is calculated and when it falls due. Last year’s accrual was carried forward from the year before.

Each levy is set by national law with its own base, its own period and its own liable person. The hours go on finding the version that applied to each quarter, working out whether the company or its local distributor is the one who pays, and writing it down so finance can accrue it.

What the research has to settle

The rules behind the answer

Two different mechanisms
Romania applies a clawback that links industry payments to public spending on reimbursed medicines. Spain requires contributions based on sales of medicines financed by its national health system. They share a purpose but differ in base, period and payer, so each needs its own analysis.
Read the version in force for each period
Both regimes are set by national legislation that can be amended. The amount for each quarter follows the rules in force for that quarter, so the note should cite the version that applied, not only today’s text.
Who is liable is its own question
National law names the person who pays. Where a marketing authorisation holder sells through a local distributor or representative, the research has to establish which of them the law makes liable, and the contracts show who bears it commercially.
Tax treatment is a separate question
Whether the levy is deductible for corporate income tax, and how it is shown in the accounts, is not answered by the levy law itself. The note should cover it separately, with its own sources.

How it runs in azta

From the question to the document

The question, as you would type it

We hold the marketing authorisations for nine reimbursed medicines sold in Romania and Spain through local distributors. For each country, what levy applies to publicly funded sales for Q1 to Q3 2026, who is liable, and how is the amount calculated and paid?
  1. You start with

    Reimbursed medicine sales in Romania and Spain, by product and quarter

  2. 01

    Ask about each levy for each period

    Name the products, the countries and the quarters. azta searches the Romanian and Spanish legislation and the Romanian tax authority material it holds.

    Cited research· Free
  3. 02

    Compare the versions over time

    Open the levy provisions in the statute reader and compare the versions in force in each quarter. Each citation shows its in-force status.

    Atlas statute reader
  4. 03

    Draft the CFO note

    Ask for a one-page note with a section per country covering base, period, liable person and open points. Edit it in Canvas.

    Canvas · Ask azta· Pro
  5. 04

    Export for the board pack

    Export to Word and keep the cited research as the working file behind the accrual.

    Word export· Pro
  6. You send

    A CFO note on each levy: base, period, liable person and open points

What you get

A CFO note on each levy: base, period, liable person and open points

CFO note · draft

Levies on reimbursed medicines: Romania and Spain, 2026

Romania. Our reading of the rules cited in the table is that the company, as marketing authorisation holder, is the liable person for its reimbursed products. The distributor agreements should be checked for any contractual pass-through. The amount for each quarter follows the version of the rules in force for that quarter.

Spain. The contribution is calculated on sales of the products financed by the national health system. The table sets out the base, the percentage and the payment schedule as stated in the provisions cited, for each product sold there.

Open points. Whether the levies are deductible for corporate income tax in each country, and whether the Romanian amount for the second quarter needs correcting, are listed for the tax team with the questions to settle.

Illustrative excerpt. A real draft is built from your facts and cites the provisions it relies on.

Outcomes on your numbers

What azta is worth on this task

Pro pays for itself after

12 minutes a month

At €140 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.

Example figures. Replace them with your own.

10%50%
Hours back a year
22
Capacity at your rate
€3,024
More levy notes a quarter
0.7
Return on Pro
9.3×
Hours a year on this task
Today90 h
Your scenario68 h
  • Research
  • Drafting
  • Your review

A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.

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Sources azta searches here

  • legislatie.just.ro
  • ANAF
  • BOE
  • EUR-Lex · Curia
See the full source register

What stays with you

  • The sales and reimbursement figures for each period.
  • Your agreements with local distributors and who bears the levy under them.
  • The accrual and the numbers the board sees.

Frequently asked questions

Does azta calculate the levy?
No. It finds and cites the rules for each period and drafts the note. The calculation uses your sales and reimbursement data and stays with finance.
Can it show the rules as they stood last year?
Yes. You can ask about the law at a past date, and the statute reader compares versions of the same provision.
Does it hold notices from the Romanian health insurance house?
azta holds Romanian legislation and the material of several Romanian authorities, including ANAF. It shows what it cites, so you can see when a notice from another body still needs checking.

Book a demo

See the CFO note built from your own case.

A working session, not a slide deck. Bring a live matter and see azta research it and draft the document, with your team in the room.

  1. 1

    Bring a real question

    One from this week, with the facts you would give a colleague.

  2. 2

    We run it in azta with you

    You watch the research and open the citations against the provision.

  3. 3

    You see the draft it produces

    Then we plan a trial with your team, if it fits your work.

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