Deductibilitatea fiscală a cheltuielilor cu serviciile prestate de către terţi

The fiscal deductibility of the management, advisory and other services raises a series of problems in order to fulfill the conditions prescribed, at art. 21 par. 4 lit. m) of the Fiscal Code and those mentioned in the Norms at point 48.The paper defends the case of contracts concluded at a global level, by the mother companies, case in which the Romanian subsidiary will not be a contractor as such.The paper is focused also on the evidence, the actual performance of the services, a matter in which the details of the Norms are not enough. The author’s opinion is that the kind of evidence depends on the nature of the service. The fiscal law can not establish a rule of evidence which is not reasonable or to expensive to procure for the taxpayer.