Cheltuieli deductibile. Cheltuieli efectuate cu logo-ul societăţii. Cheltuieli cu serviciile de asistenţă generală, cercetare şi reprezentare comercială. Condiţii pentru exercitarea dreptului de deducere. Sarcina probei în dovedirea situaţiei de fapt fiscale

Deductible expenses. Expenses made with the company logo. Expenses with the general assistance, research and commercial representation services. Conditions to exercise the right of deduction. Burden of proof in proving the tax situation

Abstract

According to art. 65 par. (1) of the tax procedure Code, the burden of proof in proving the tax situation falls on the tax payer.

In interpreting the provisions of art. 21 par. (4) letter m) of the tax Code and the implementation rules, the existence of contracts is a necessary condition for acknowledging the deductibility of expenses, however not sufficient; the tax payer must prove cumulatively that the services were actually provided and that they were directly connected with the company’s...