With regard to entities providing freight forwarding services, excluding those operating road freight transport, Decision No. 194/2023 stipulates that proceeds derived from recharging transport services actually performed by third-party carriers on behalf of the principal are excluded from total revenues, provided that these services are not rendered by non-resident entities with no permanent establishment or tax representative within the State territory. For the identification of the relevant revenue for sea and air shipments, Article 2 (14) of Decision No. 194/2023 refers to the rules established for maritime transport and air carriers, respectively.
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