RTPR has successfully represented the interests of Sumiriko AVS Romania before the High Court of Romania.
Sumiriko AVS is a producer of spare parts and equipment for the automotive industry.
According to RTPR, the proceedings concerned the fact that “expenses for intra-group research and development do not represent royalties for transfer of know-how, but the provision of services.”
According to the firm, “in this case, the General Directorate for the Administration of Large Taxpayers considered that in the situation of the existence of a research and development agreement concluded at the level of the group, the expenses incurred by the members of the group represent royalties for the transfer of know-how and not the provision of services." Both the Oradea Court of Appeal and the HCCJ ruled that the company correctly addressed the fiscal treatment of these expenses.
The RTPR team included Counsel Alexandru Stanoiu and Senior Associate Ana Popa Nedelcu.
