ECJ Ruling OKs Pricing Rules For Int'l Bank Transfers
Law360 (October 8, 2020, 7:09 PM EDT) -- European Union member countries can apply transfer pricing regulations to bank transfers between branches located in different bloc countries, Europe's top court ruled Thursday, dealing a setback to the tax protest of an Italian company's Romanian branch.
The European Court of Justice ruling could imperil Impresa Pizzarotti's bid to recoup about €525,000 ($617,000) in tax assessed by Romanian authorities for issuing loans with no interest provisions to its Italian parent construction company, Pizzarotti Italia. The loans, issued in 2012, had a combined value of €13.7 million, the ruling said.
A Romanian national court, the Tribunalul Cluj, will make the ultimate decision...
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