Author: Courts of Romania

Romania vs S.C. A., March 2021, Supreme Administrative Court, Case No 1955/2021


S.C. A. had paid for intra group services in FY 2013 and 2014 and deducted the costs for tax purposes. The purchases of services were made on the basis of a management services contract concluded with related party C. S.A. and a production service contract, logistics service contract, product management service contract and service contract […]

Romania vs Lender A. SA, December 2020, Supreme Court, Case No 6512/2020


In this case, A. S.A. had granted interest free loans to an affiliate company – Poiana Ciucas S.A. The tax authorities issued an assessment of non-realised income from loans granted. The tax authorities established that the average interest rates charged for comparable loans granted by credit institutions in Romania ranged from 5.45% to 19.39%. The […]