Ordinul ANAF nr. 828/2026: rescrie regulile privind dosarul prețurilor de transfer
ANAF Order No. 828/2026: rewrites the rules on transfer pricing file

Summary/Abstract: Order No. 828/2026 of the President of the National Agency for Fiscal Administration (ANAF), published in the Official Gazette No. 543 of 2 July 2026, introduces the most comprehensive revision in recent years of Romania’s transfer pricing documentation rules. Key changes include a new obligation for large taxpayers to prepare and electronically file the transfer pricing file every year, through the Virtual Private Space (SPV); revised materiality thresholds, now assessed separately for each transaction and each related party; new standardised reporting annexes for intra-group transactions; and a significant expansion of the file’s content requirements. Herein after we have included a summary of the main changes brought by the new order as well as practical guidance for taxpayers who need to align with the new requirements starting with transactions carried out in fiscal year 2026.

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