Transfer pricing

We can offer guidance on transfer pricing matters and can assist you with your intra-group transactions.

Current developments within the OECD and the European Union alongside globalization of trade and further expansion of multinational corporations led to the transfer pricing issue becoming one of the most important matters which are faced nowadays by multinationals, as well as local companies.

Tax authorities’ scrutiny on the matter has also became stronger.

Following the international trend, the Romanian transfer pricing legislation requires local companies to have transfer pricing documentation available based on which tax authorities can assess the compliance with the arm’s length principle.

In this context, our specialised team of tax consultants has the capacity, knowledge and vast experience required to assist you in complying with the current Romanian transfer pricing regulations or going through a tax inspection. To cover cross-border complex implications, we work together with transfer pricing experts in Taxand, in view of mitigating adverse tax consequences like double taxation or penalties for non-compliance of legal requirements in various jurisdictions.

Our transfer pricing related services include:

  • Design and prepare transfer pricing policies at group or company level;
  • Review supply chain transactions and advice on transfer pricing matters, in direct correlation with the indirect tax consequences;
  • Preparation of transfer pricing files (master file, country file), Country by Country reports and notifications;
  • Review of existing transfer pricing policies and documentation or guidance in preparing the required files;
  • Drafting and negotiation of Advance Pricing Agreements (APA);
  • Dispute resolution services: representation and assistance during fiscal audits, assistance during the administrative appeal stage and judicial expertise services, MAP procedures.