The High Court of Cassation and Justice has recently upheld a decision of the Timisoara Court of Appeal, with significant relevance for transfer pricing disputes based on the re-qualification of the functional profile of a company within a multinational group from independent producer to producer under the full control of the group. It has been confirmed that elements specific to the operation of a multinational group, such as providing support services by global cooperation structures or the existence of common directors, do not prove the existence of a transaction between the parent company and the controlled entity that would justify reconsidering the functional profile of the company, even in cases where the controlled entity experienced periods of losses.
The High Court of Cassation and Justice of Romania has recently rendered a particularly relevant decision, significant for disputes involving administrative support services provided within a multinational group operating in the energy sector.
On October 22, NNDKP and Ziarul Financiar will organize the 9th edition of the annual Legal & Tax conference, which aims to analyze the main legal and tax issues that companies in Romania need to consider at the end of the fiscal year.
On October 22, Daniel Hadar, Tax Director, NNDKP Cluj-Napoca office, will be a speaker at the first edition of the CFO Conference Oradea, organized by Business Mark at Ramada Hotel.
On September 15, Alina Timofti, Tax Partner, NNDKP Tax Advisory Services, and Emil Bivolaru, Executive Partner, spoke at the special edition of ZF Live, “How is the market for tax disputes between the state and companies evolving?”, moderated by Cristian Hostiuc.
Author: Alexandru Aparaschivei
Ordinance no. 22 for the amendment and completion of the Tax Code, with an impact on small enterprises, was published in the Official Gazette no. 806/29.08.2025
