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ICCJ and DGSC invalidate certain illegal ANAF practices often encountered in transfer pricing inspections

ICCJ and DGSC invalidate certain illegal ANAF practices often encountered in transfer pricing inspections

The dismissals given by the High Court thus appear extremely relevant and edifying in terms of transfer pricing

The issue of transfer pricing remains one of the areas of interest for tax inspection bodies. Thus, companies face transfer pricing adjustments generated by the modification or even replacement by tax authorities of comparability studies by including / excluding comparables, without being based on a proper justification based on alleged deficiencies in the transfer pricing file prepared by companies.

For more information, please see the Romanian version of the article, here.

Authors

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PRICEWATERHOUSECOOPERS SERVICII SRL
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D&B DAVID SI BAIAS SCA