Author: Courts of Romania

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

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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

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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 […]