Instituţia suspendării inspecţiei fiscale – corelaţia dintre dreptul fiscal și dreptul comun
Numărul 6 Anul 2021
Irrespective of the legal relation it is applied to, the suspension should not have ratio legis, permanent consequences. In other words, the suspension as a procedural instrument, should preserve the substance of the legal relation and delay the review or evolution thereof. In terms of tax inspection, article 127 of the Code of Tax Proceedings is no exception either, since it is a legal instrument necessary, yet proportionally applicab...Citește mai mult
Impozitarea nerezidenților în Noul Cod fiscal: Treaty override?
Numărul 11 Anul 2016
This paper deals with the relationship between the double tax treaties and the methodological rules for the application of Fiscal Code with a focus on the ”net of tax contractual” provisions which are frequently used in the agreements concluded with non-residents. In our view, the provisions from the methodological rules which prevent the application of double tax treaties when the tax is borne by the Romanian income payer override the treaty...Citește mai mult
© 2022 Wolters Kluwer