S.C. X S.R.L. has as its object of activity “Manufacture of aircraft and spacecraft”, CAEN code 3030.
Period audited: 01.01.2016 – 31.12.2021.
The main results of the tax inspection authorities were:
- Adjustments of expenses following the analysis of the transfer pricing file for the period 01.01.2016 – 31.12.2020. Based on the verification of the accounting registration of interest expenses, recorded by the company on non-bank loans acquired during the period under review from affiliated companies, compared to the tax declared by the company, an additional corporate income tax in the total amount of x lei was established for the period 2016-2020;
- Intra-community supplies that did not fulfill the conditions for the application of the value added tax exemption regime, VAT was collected in the amount of x lei;
- VAT without the right to deduct in respect of services invoiced by the affiliated supplier S.C. Y, in the amount of x lei, no supporting documents were submitted to prove that the services were performed for the benefit of the taxable operations of the audited company;
- For the interest payments exceeding the market value, additional tax was assessed on the income obtained by non-residents, totaling RON x, and additional tax on the commission income obtained in Romania by non-residents, totaling RON x.
– As a result of the tax inspection, additional tax liabilities totaling x lei were established, of which:
- x lei VAT;
- x lei corporate income tax;
- x lei income tax on income from services rendered in Romania and outside Romania by non-resident persons;
- x lei tax on commission income obtained in Romania by non-resident persons;
- x lei tax on interest income obtained in Romania by non-resident persons.
Source: ANAF