On 8 October 2020, the Court of Justice of the European Union (CJEU) issued a judgment concerning whether Romania may apply its transfer pricing rules on bank transfers (loans) from a branch to its parent in another Member State. The case involved Impresa Pizzarotti, which is the Romanian branch of SC Impresa Pizzarotti & C SPA Italia (Pizzarotti Italia), established in Italy.
During the period between 29 July 2016 and 11 September 2017, Romania's tax authority carried out an inspectio…