Modificări importante la legislația de prețuri de transfer în România
Significant Changes to Transfer Pricing Legislation in Romania
Author(s): Nadia OaneaSubject(s): Law, Constitution, Jurisprudence, Commercial Law
Published by: Editura Solomon
Keywords: Transfer pricing documentation; comparability analyses; Advance Pricing Agreement; compliance obligations; standardized documentation;
Summary/Abstract: At the beginning of July 2026, significant changes were introduced to Romania’s transfer pricing legislation: Order no. 828/2026 – new rules regarding transfer pricing documentation (TPD), comparability analyses, thresholds, deadlines, and transfer pricing adjustments. Order no. 827/2026 – a revised regime for the Advance Pricing Agreement (APA), including the possibility of extending APAs to previous years. The overall direction is clear: ANAF is moving toward significantly more detailed, substance‑based documentation, increased transparency, earlier compliance obligations, and more standardized comparability analyses.
Journal: Tax Magazine
- Issue Year: 2026
- Issue No: 3
- Page Range: 185-196
- Page Count: 12
- Language: Romanian
- Content File-PDF
