Reîncadrarea tranzacțiilor și ajustarea efectelor fiscale ale acestora. Studiu de caz
Reclassification of transactions and adjustment of their tax effects. Case study
Author(s): Mirel MorcovSubject(s): Law, Constitution, Jurisprudence, Civil Law
Published by: Universul Juridic
Keywords: article 11 Fiscal Code; dividend tax; transaction requalification; case law; High Court of Cassation and Justice;
Summary/Abstract: In the light of recent case law of the High Court of Cassation and Justice, the extremely broad limits of the tax authority’s assessment of the reclassification of a legal transaction and the adjustment of its tax effects are being reconsolidated. The article aims to analyze a recently resolved case in which a sale-purchase transaction has been reclassified as dividend distribution.
Journal: Revista Consultant Fiscal
- Issue Year: 2021
- Issue No: 02
- Page Range: 21-25
- Page Count: 5
- Language: Romanian
- Content File-PDF