www.economica.net/consultantii-fiscali-atrag-atent

The Chamber of Tax Consultants (CCF) criticizes the PL x 694/2026 project for potentially imposing double taxation on the same amount, affecting both Romanian and foreign groups. The project does not differentiate between real and artificial transactions and reinstates a previously abolished measure recommended by the OECD. It proposes that management and consultancy costs within groups become non-deductible, which could lead to increased fiscal burdens for companies. Additionally, interest on loans from group companies would only be deductible up to a certain limit, potentially raising borrowing costs. CCF identifies several flaws in the project, including its disproportionate impact on legitimate business expenses and the risk of legal challenges under EU law.