Comeback and final victory before the Ploiesti Court of Appeal for RTPR’s tax litigation team for Rosti Romania SRL: adjustment of the tax loss made by estimation deemed illegal; the transfer pricing file not contested by the tax authorities must be taken into account

Teona Gherasim

In the present case, the Regional Directorate of Public Finance Ploiesti – AJFP Prahova considered in 2019 that the accounting loss recorded by the Company should be adjusted, the fiscal situation being retained exclusively by estimate, ignoring all the accounting records of the Company, including the transfer pricing file. After 7 long years, sprinkled with victories, scraps and referrals for retrial, the taxpayer’s ordeal ended with a definitive victory, the Ploiesti Court of Appeal ruling