S.C. X S.R.L. has as its object of activity “Manufacture of other parts and accessories for motor vehicles and their engines”, CAEN code 2932.
Period audited: 01.01.2021 – 31.12.2023.
The main results of the tax inspection authorities were:
Concerning corporate income tax:
- the audited company did not perform the adjustment of income realized in the period 2021-2022 from transactions with affiliated persons, based on the transfer pricing file, thus it did not comply with the market value principle, as required by Art. 11 para. (4) of Law no. 227/2015 on the Tax Code, as amended;
- the audited company did not re-invoice in the years 2021 and 2022 the expenses registered in the account 628 “Other expenses with services performed by third parties”, representing hotel rental and accommodation services for employees of company X from Member State X seconded to S.C. X S.R.L., for the provision of assistance services necessary for the establishment of S.C. X S.R.L.;
- the audited company registered in account 601 “Expenditure on raw materials” an inventory loss registered in the minutes of the annual inventory, which was not justified;
- registered various expenses in the financial accounting records for which it did not submit supporting documents.
Thus, additional corporate income tax in the amount of x lei was established.
With regard to value added tax, as a result of the above, the company erroneously deducted VAT in the amount of x lei, which represents additional VAT established by the tax inspection authorities .
Total additional tax liabilities established in the amount of x lei, representing:
- x lei corporate income tax;
- x lei VAT.
Source: ANAF