De la strategie la conformare: mecanisme preventive și post-factum în gestionarea prețurilor de transfer
From strategy to compliance: preventive and post-factum mechanisms in transfer pricing management
Author(s): Cristina Niculcea, Mădălina VișanSubject(s): Law, Constitution, Jurisprudence, Law on Economics, Commercial Law
Published by: Editura Solomon
Keywords: transfer pricing; Advance Pricing Agreements (APA); Mutual Agreement Procedure (MAP); double taxa on; tax cooperation; tax compliance; tax certainty; fiscal stability;
Summary/Abstract: 2025 marks a new stage of maturity in transfer pricing, defi ned by a more cooperative and transparent framework between taxpayers and tax authorities. The new regulations strengthen fiscal predictability and stability, offering companies modern tools for compliance and dispute prevention. In this context, Advance Pricing Agreements (APA) act as preventive instruments for validating transfer pricing methodologies in advance, while Mutual Agreement Procedures (MAP) provide post-factum remedies to eliminate double taxation. Together, these mechanisms reflect a modern approach based on transparency, cooperation, and fiscal certainty
Journal: Tax Magazine
- Issue Year: 2025
- Issue No: 5
- Page Range: 376-382
- Page Count: 7
- Language: Romanian
- Content File-PDF
