HYPERION ECONOMIC JOURNAL

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• Mariana Manea, PhD Student, Affiliation: Poly-Technical University of Bucharest, Romania;

Multinational companies operating in several states fiscally optimise their business by “choosing and implementing the optimal (economic) solution (out of various possibilities)” . In some cases, tax optimisation takes aggressive forms with the aim of avoiding tax obligations.
Aggressive tax optimisation is mainly aimed at obtaining tax advantages through cross-border intra-group arrangements, successive transactions, the fragmentation of activities among group entities and price manipulation.
The DAC 6 Directive and the Multilateral Convention (MLI) as well as the latest rulings of the CJEU recommend limiting the avoidance of taxes in the state where the profit is made, and a major role in this regard is played by control institutions.

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