Transfer pricing represents the mainstream agenda in the light of tax law, lato sensu, and international taxation, stricto sensu. At the international level, there can be an emphasis on several problems related to taxation: double taxation, double non – taxation, permanent establishment, business profits, residence criteria, arm's length principle, mutual agreement procedure, dispute resolution of tax conflicts. However, the problem of transfer pricing has more profound judicial and economic implications. The main objective of this paper is to evaluate and assess the underlying features and characteristics of transfer prices in the economical and judicial actual context. The operational objectives are related to a quid pro quo analysis regarding the fine-tuning aspects of transfer pricing in the digital taxation era. The case law presented in this article tackles the main problems of applying transfer pricing international regulation upon Romanian tax jurisprudence. The conclusion of this article highlights the need, mutadis mutandis, for a tax policy agenda revealing a strengthened fiscal and financial environment towards the creation of a new proper fiscal space.
The paper aims to prove the link between human capital and gross added value in bioeconomy sectors in the EU countries. Data from EUROSTAT data base regarding employment and gross added value in 6 bioeconomy sectors were used in a cross-country regression analysis. The econometric analysis of cross-country data shows a positive correlation between human capital in bioeconomy sectors and their gross output in 2015 in 26 European countries. It is found also that the correlation is stronger in the highly developed economies as in the central-eastern countries, as well as in the European economy.
Nowadays, around the world, it can be noticed an important trend towards the pension system reforms. The creation of the European fiscal space, the effects of globalization and the movement of the labour force are important vectors towards creating a new type of social economy. The labour force is constantly moving around the countries that gathered important amounts of capital, especially in industrialized countries. Moreover, the lower levels of the birth rate combined with the increasing level of death rate unbalance the labour market. The entire European continent undergoes a demographical transition period, highlighted by aging and intensive migration. This phenomenon is registered both outside and inside the European Union, especially upon the highest industrialized Western countries. In this context, the human capital role and quality gain an important topic throughout the social and economic developments. In this article, we tackle some important aspects regarding the correlation between the actual status quo of population structure and some important features of future pension systems.
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