S.C. X S.R.L. as activity “Manufacture of electrical and electronic equipment for motor vehicles and motor vehicle engines”, CAEN code 2931.
Verified period: 01.01.2016-31.12.2022.
The main findings of the tax inspection authorities were:
Following the analysis of the functions performed, the risks assumed and the assets used in the transaction consisting of the production/sale of finished products to related parties, the tax inspection established that S.C. X S.R.L. acted as a contract manufacturer with limited functions and risks specific to the activity and structure of cooperation with the related companies, and the latter purchase the finished products and are subsequently responsible for their placement/sale to their own customers.
The audit also found an erroneous allocation of some revenues invoiced to third parties (revenues from the sale of residual products, from various re-invoicing) as revenues obtained from affiliates, with the consequence of further distorting the values of the profitability indicators calculated in relation to affiliated partners. Following the analysis of the information recorded in the TPD and the replies to the requests of the tax inspection authorities , the level of the profitability indicator was recalculated for the whole period audited.
(ROTC) obtained by S.C. X S.R.L. from the sale of finished products to affiliates.
Thus, the tax inspection authorities adjusted the operating income for the production sold to affiliates, recalculating the level of income from this activity.
Following the analysis of the conformity with market prices of the transaction represented by the sale of goods resulting from the production activity to affiliated legal entities, the tax inspection resulted in adjustments to the operating income of S.C. X S.R.L. in the total amount of x lei.
The difference of MDL x represents the value added tax related to some purchases of goods and services made by S.C. X S.R.L. during the audited period.
Source: ANAF