S.C. X S.R.L. has as its object of activity “Wholesale of electronic and telecommunications components and equipment”, CAEN code 4652.
Period audited: 01.01.2013 – 31.12.2018.
The main observations of the tax inspection authorities were:
In the period 2014-2018, expenses were recorded in the accounting records in account 623 – “protocol, advertising and publicity expenses”, expenses for sales promotion in the total amount of x lei, based on “debit notes” representing services rendered, without submitting attached supporting documents and/or supporting documents.
The audited company did not submit to the tax inspection authorities any documents (activity reports, time sheets, minutes, etc.) proving that the contracted services were actually rendered, what they consisted of, the deadlines for their execution, etc., and it was not possible to indicate the persons who rendered the services or the benefits that were brought to the audited company.
Thus, the amount of x lei represents non-deductible expense for the calculation of taxable profit.
Also, the tax inspection authorities found that in 2014-2015, the company X S.R.L. recorded in its accounting records purchases of services from the supplier Y Branch X in the total amount of x lei, of which VAT in the amount of x lei.
From the analysis of the documents submitted by the audited company, the tax inspection authorities found that the company Y Branch X does not have the status of a service provider, it did not concretely emerge what is the activity provided by the company Y Branch X. The fact that the audited company submitted to the tax inspection authorities photos/records of delivery-receipt (in most cases the company Y Branch X being the recipient), the fact that some photos had the stamp of the company Y Branch X, was not relevant in justifying the amounts paid by S.C. X S.R.L.
Source: ANAF