Sinteză de jurisprudență fiscală națională
Synthesis of national tax case law

Summary/Abstract: Services purchased from affiliated parties. Deductibility conditions. The beneficiary test. The principle of proportionality Intra‑group services must be analyzed through the lens of the beneficiary test, verifying whether they generate a concrete benefit for the company and whether they are effectively attributable to it. Classifying services purchased from affiliated parties as “intra‑group services” cannot, in itself, exclude the possibility that the related costs fall within the scope of shareholder or shareholding‑related expenses; rather, it requires a concrete, case‑by‑case examination of the contractual content, the utility, and the connection with the company’s activity.

• Details
• Contents