The team of lawyers from STOICA & ASOCIAȚII, composed of Valeriu Stoica – Founding Partner –, Dan-Rareș Răducanu – Senior Partner – and Oana Zamă – Partner –, obtained an important victory for a client in a dispute concerning the annulment of administrative -fiscal decisions establishing additional payment obligations in the amount of 21,771,123 lei, representing income tax, and 17,053,335 lei, representing VAT, to which surcharges and late payment penalties were to be added.
By civil decision handed down on March 11, 2026, the High Court of Cassation and Justice fully confirmed the decision handed down by the Bucharest Court of Appeal on June 10, 2025, in a dispute in which complex evidence was administered, including an expert report prepared by a commission of three judicial experts who were also tax consultants.
"Additional tax liabilities were imposed on the client, as the control authorities and, subsequently, the appeal resolution body, disallowed a series of intra-group expenses from deductibility, considering them to be fictitious. The dispute involved the administration of extensive evidence, including an expert opinion prepared from the outset by a commission of three judicial experts who also acted as tax consultants, which is less common. Importantly, working in an interdisciplinary team alongside our client, we were able to demonstrate that the supporting documents already analyzed by the tax authorities attest to the reality of the services, and that any formal defects in those documents, from the perspective of legislation other than tax legislation, are irrelevant from this perspective. At the same time, the courts have once again rightly ruled that the appropriateness of providing services, even within a group, cannot be subject to analysis by the tax authorities. The judicial settlement of these issues will set a precedent for similar tax disputes," said Dan-Rareș Răducanu, Senior Partner.
With a history of over 30 years in the business law market, STOICA & ASOCIAȚII has gained national and international recognition in the world of law and business through its legal assistance and representation of a vast portfolio of clients. Since its establishment in 1995, the lawyers at STOICA & ASOCIAȚII have proven themselves to be a strong team, based on respect for its principles: Fidelitas, Integritas, Fortitudo. STOICA & ASOCIAȚII has earned an excellent national and international reputation. Its professional achievements are recognized in the most important legal guides: Chambers Europe, Legal 500, WTR 1000, IAM Patent 1000.
