Allocation of intangibles and risks within corporate groups – implications of BEPS

In adopting a stronger focus on the taxation of economic activities at the place where value is effectively created, the OECD wants to counteract mainly tax-aggressive models of large corporate groups (shifting profits to low-tax rate countries). But the aspects of intangibles and allocation of functions and risks within corporate groups discussed in the light of "Base Erosion and Profit Shifting" (BEPS) relate to not only large companies but also SMEs and their international business models.

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The National Agency for Fiscal Administration (ANAF) intends to strengthen controls on transfer pricing

This year will bring, along with the entry into force of the new Tax Code, tightened controls from The National Agency for Fiscal Administration (ANAF) regarding the transfer pricing documentation, an area considered of high fiscal risk by the authorities.

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The submission of Statement 101 regarding the profit tax

According to the provisions in force, Statement 101 is annually prepared by profit tax payers and submitted until the 25th of the third month after the closure of the fiscal year. The submission of the statement regarding the profit tax for year 2015 shall be made according to the provisions of article 42 of Law 227/2015 (Tax Code).

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Fiscal news regarding the tax regime of sole traders and microenterprises

The new Tax Code brings, along with its enforcement on the 1st of January 2016, amendments concerning the fiscal regime applicable to registered sole traders and to microenterprises, raising questions regarding the selection of the best manner to perform the activities, from the fiscal point of view.

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Transfer Price - News 2016

According to the Tax Code enforced at the beginning of this year, all companies operation transactions with affiliated persons are obliged to prepare the transfer price file. The most recent obligations are provided in the new Fiscal Procedure Code - Law 207/2015.

 

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