Directive 1852/2017 transposed to the national legislation

On August 22nd 2019, Romania transposed the EU directive 1852/2017, which establishes a system that promises the elimination of misunderstandings between EU Member States regarding the application of the provisions of bilateral treaties and other international agreements of conventions. Thus, the companies will have through these new provisions an instrument that will give them a […]

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Taxpayers will be able to argue more effectively against transfer pricing readjustments following a key ruling on the arm’s-length principle in the Hornbach-Baumarkt case

The ECJ ruled that member state tax rules are proportionate (and therefore in line with EU law), saying taxpayers in the EU have the right to demonstrate that they may have had commercial reasons for failing to meet the standard required of the arm’s-length principle. Facts of the case This time, the ECJ ruled on […]

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B.E.P.S. implementation: Multilateral B.E.P.S. Convention will enter into force on July 1st

Base Erosion and Profit Shifting (B.E.P.S.) refers to tax planning strategies, that exploit gaps and actual mismatches in tax rules that allow the artificial shift of profits to loss or non-tax locations where there is little or no economic activity, which takes to little or no overall corporate tax being paid. In the attempt to […]

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