C-558/19Impresa Pizzarotti & C SpA Italia Sucursala Cluj v Agenţia Naţională de Administrare Fiscală - Direcţia Generală de Administrare a Marilor Contribuabili

Domstolens egne nøkkelord

Reference for a preliminary ruling – Articles 49 and 63 TFEU – Freedom of establishment – Free movement of capital – Calculation of the taxable income of companies – Persons having a relationship of interdependence – Unusual advantage granted by a resident branch to a non-resident company – Correction of the taxable income of the branch of a non-resident company – No correction of taxable income in the event of an identical advantage granted by a branch to a resident company – Principle of free competition – Restriction on freedom of establishment – Justification – Balanced allocation of the power to tax between Member States – Proportionality.

Tolker