As is known, by art. 6 of Law nr. 241/2005 for preventing and combating tax evasion was criminalized the act of withholding and not paying, intentionally, within a period exceeding 30 days from the due date, the amounts representing taxes or contributions with withholding at source. Until the entry into force of this normative act, such an act was regulated in a slightly different form, being sanctioned only contravention, in art. 13 para. (1) ...

The holding companies have played, in time, an important role in both hiding the assets from tax authorities of the competent states and the identity of the funds’s real beneficiaries. This types of entities were, regularly, incorporated in fiscal paradises which offered a more advantaged tax regime than the ones where the companies performed their main activities. In the light of the latest international provisions regarding the exchange of i...