The problem of the bona fide taxpayer who, by mistake, registers for VAT purposes and, consequently, collects VAT from invoices relating to exempt transactions without the right to deduct, is likely to place the corrective and punitive mechanisms of national law and the fundamental principles of European Union law in conflict. Following the tax inspection, although the main VAT obligation is corrected (by cancelling the unjustified deduction ...

The new Fiscal Procedure Code, in force on 1st of January 2016, addresses once more the issue of payment facilities but from a new perspective, allowing for a codification of the existent regulations in this field and offering a real support for contributors acting in good faith but found in financial struggle.In this newly created context, the fiscal legislator establishes a true payment facility procedure that we have structured in the ...

This paper purpose is to identify the historical reasons which underlie the current tax treatment of the interest payments under the Model Conventions elaborated by the Organization for Economic Cooperation and Development and by the United Nations. Although similar from the regulatory point of view, the different treatment of the interest income under the two Model Conventions is important, mainly due to their general purposes and to the way t...