OPTIMIZARE SAU EVAZIUNE FISCALĂ? VIZIUNEA CODULUI FISCAL ŞI A NORMELOR SALE DE APLICARE RAPORTATE LA LEGEA EVAZIUNII FISCALE
Optimization or tax evasion? The consideration of the Tax Code and of its enforcement rules related to the law on tax evasion

Summary/Abstract: In this study, the author deals with the consideration of the Tax Code and of its enforcement rules related to the law on tax evasion. The structure and the body of the study reveal the comments on the regulation of the tax evasion crimes, on the concept of tax evasion, on the tax optimization and tax fraud (concealment of the agreement, transfer prices, concealment of the holder of taxable income, choosing the tax residence, management of differences in the treatment of a taxpayer or of an operation or transaction based upon the laws of two or several States, use of the deductibility of interests of intra-group loans), taking into consideration, for the purposes of the above-mentioned, the doctrine developed by certain important names in the field of law (N. Cârlescu; D. Dascălu, I.T. Ştefănescu, I.M. Costea, P. Diaconu, I.P. Filipescu, I.L. Georgescu, E. Petit, R.B. Bobei, M.A. Dumitrescu, N.R. Dominte, D.A. Popescu, D. Pătroi, F. Cuciureanu, V. Radu). Finally, the author puts forward certain brief considerations regarding the deductibility of interests of intra-group loans.

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