Regimul împrumuturilor intra-grup
Intra-group loans

Summary/Abstract: This paper examines generally the legal treatment and specifically the tax treatment of the intra-group loans. The analysis highlights that there might by a contradiction between the special laws, which regulate the crediting activity, allowed only to certain entities, under the strict surveillance of N.B.R., and the tax provisions, domestic and of the EU, which regulate the effects of the loan agreements concluded between entities belonging to the same group of companies and not observing the banking requirements. The authors plead for a teleological and consistent with the EU law interpretation of the national provisions, without affecting the special nature of the analysed provisions.

• Details
• Contents