Adevărul fiscal în sistemul procedural naţional, explicaţii privind Directiva privind preţurile de transfer COM (2023) 592 final

Ph.D. Lavinia POPESCU

Consilier Deloitte România

Bucharest University of Economic Studies, Romania

Ph.D. Adela Sorinela SAFTA

Expert superior ANAF

Bucharest University of Economic Studies, Romania

ABSTRACT

A significant volume of world trade consists of international transfers of goods and services, capital and intangible assets within multinational enterprises.

As a result of the different tax systems from country to country, these transactions de facto reflect that they are not governed by the market, and can be primarily determined by the common interests of the group. These transactions distribute a burden on the entities’ income and/or expenses. Considering that the taxes follow the general principles, based on the accounts at the entity level, the prices as well as any other conditions in which these transactions take place within the group have effects on the...