When is a transfer pricing file mandatory in Romania?
It depends on the taxpayer category and the value of the intra-group transactions. Large taxpayers usually prepare it every year, while the others prepare it at the request of the authorities.
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Transfer pricingdocumentation in Romania
The transfer pricing file is the documentation that justifies transactions between related companies according to the arm's length principle. It has been required in Romania since 2008 and shows that intra-group transactions take place at prices comparable to those between independent parties.
Taxpayers with significant intra-group transactions must prepare the file every year, while the others prepare it at the request of the tax authorities. The deadlines for presenting it are strict.
Extended transparency rules, such as country-by-country reporting (CbCR) and the reporting of cross-border arrangements (DAC6), give the tax authorities much more information, so intra-group transactions are checked more closely than ever.
A missing or late file allows the inspectors to adjust transfer prices, which can have a significant financial impact and is difficult to challenge later.
What our transfer pricingservice includes
- mapping intra-group transactions and the applicable thresholds;
- functional analysis of each related entity's roles, assets and risks;
- benchmarking and selection of the appropriate pricing method;
- drafting the complete transfer pricing file in line with Romanian rules;
- support during ANAF tax audits and in answering the inspectors' requests.
How we preparethe file
Mapping transactions
We list the intra-group transactions and the thresholds relevant for documentation.
Functional analysis
We establish the roles, risks and contributions of each related entity.
Benchmarking
We apply the comparability analysis and support the pricing policy.
File and ANAF support
We draft the complete file and support you during any tax audit.
Frequently asked questionsabout transfer pricing
What are the risks if the file is not ready on time?
Tax adjustments, penalties and difficulty defending the pricing policy between related companies.
What does your service include?
Functional analysis, benchmarking, documentation of intra-group transactions, drafting the file and support in dealings with ANAF.
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