Period audited: 01.01.2017 – 31.12.2022.
The main results of the tax inspection authorities were:
In order to determine the operating income to be adjusted during the audited period, related to the transactions between the audited company and affiliated customers, the tax inspection authorities took into account the following:
- the operating income recorded in the period 2017-2022 for the total activity carried out with affiliated clients (adjustment of the operating income recorded in relation to clients for the purpose of increasing it);
- the median value established by the tax inspection authorities in the transfer pricing file for the selected independent comparable companies for production activity;
- the profitability indicator of the audited company, which is below the market range;
- RRV indicator calculation formula, since the audited company’s result was not within the interquartile range, the tax inspectorates calculated it at the median level established for independent comparable companies and proceeded to adjust the operating income recorded in relation to affiliated customers.
In conclusion, as a result of the tax inspection carried out, the tax inspectorates established additional corporate income tax in the total amount of x lei.
Source: ANAF