S.C. X S.R.L., has as object of activity “Manufacture of other rubber products”, code CAEN 2219.
Period audited:
01.01.2016 – 31.10.2022 VAT;
– 01.01.2017 – 30.09.2022 corporate income tax.
The main findings of the tax inspection bodies were:
Company X S.R.L. – Romania is part of Group X, having as sole shareholder company T from Member State X, which holds 100% of the share capital. During the period audited, the company was engaged in the activity of metal confections, the production being mainly delivered in the European economic area.
The tax inspection bodies found that S.C. X S.R.L. carried out transactions of significant values, above the threshold established in Order 442/2016 with affiliated companies in the nature of purchases and deliveries to related parties, defined according to Article 7, item 26 of Law no. 227/2015 on the Tax Code as amended.
The analysis carried out by the tax inspection bodies on the TPD showed that the audited company does not fall in any year within the interquartile range, S.C. X S.R.L. considering that the transactions were carried out in accordance with the provisions stipulated in the contracts concluded with its affiliated parties, in compliance with the market value principle, for purchases of raw materials and deliveries of finished products selecting the net margin method of trading.
Therefore, in accordance with the legal provisions, the income was adjusted to the central market trend, resulting in additional income in the amount of MDL x, and taking into account the amounts calculated and declared by the company in the corporate income tax return (D 101), the tax inspection team recalculated the corporate income tax base and recalculated the additional corporate income tax.
As a result of the tax inspection carried out, the tax loss declared by the company was reduced by the amount of x lei, and additional corporate income tax was calculated in the amount of x lei.
Source: ANAF