STOICA & ASOCIAțII obtains for a client the cancellation of tax obligations in the amount of 8 million Euros

The team of lawyers from STOICA & ASSOCIAțII, composed of Valeriu Stoica – Founding Partner -, Dan-Rareș Răducanu – Senior Partner – and Oana Zamă – Partner -, achieved an important victory for a client in a litigation with the object of canceling some administrative-fiscal documents through which additional payment obligations of 21,771,123 lei were established, representing profit tax and 17,053,335 lei, representing VAT, to which increases and late penalties were to be added.

Through the civil decision handed down on March 11, 2026, the High Court of Cassation and Justice fully confirmed the solution handed down by the Bucharest Court of Appeal on June 10, 2025, in the context of a litigation in which complex evidence was administered, including an expertise drawn up by a commission of three judicial experts, also having the capacity of fiscal consultants.

“The additional fiscal obligations were determined to be borne by the client, since the control bodies and, subsequently, the body for resolving the appeal, removed from deductibility a series of intra-group expenses, abusively considering them to be fictitious. The litigation involved the administration of extensive evidence, including expertise conducted from the outset by a panel of three judicial experts who also served as tax consultants, which is less common. The important thing is that, working in an interdisciplinary team, together with our client, we managed to demonstrate that the supporting documents already analyzed by the fiscal bodies attest to the reality of the services, being irrelevant, from this perspective, the existence of some defects in their form, from the perspective of legislation other than the fiscal one. At the same time, the courts rightly assessed, once again, that the opportunity to provide some services, even within the group, cannot form an object of analysis by the tax authorities. The judicial resolution of these issues will be a benchmark for similar litigation in tax matters” said Dan-Rareș Răducanu – Senior Partner.

With a history of over 30 years in the business law market, STOICA & ASOCIATII has gained national and international recognition in the world of law and the business environment, through its entire activity of legal assistance and representation of a vast portfolio of clients. From the establishment in 1995 until now, the lawyers of STOICA & ASSOCIATII have proven that they are a strong team, based on the observance of its principles: Fidelitas, Integritas, Fortitudo. STOICA & ASSOCIAțII has acquired an excellent national and international reputation. His professional achievements are recognized in the most important legal guides: Chambers Europe, Legal 500, WTR 1000, IAM Patent 1000.

Article supported by STOICA & ASSOCIAțII