We present a summary of the main amendments and additions to certain normative acts with fiscal implications, published in July 2025. 

(Official Gazette no. 695 of 24.07.2025)

Ordinance no. 11/2025 brings amendments and clarifications to the Law no. 207/2015 regarding the Tax Procedure Code as follows: 

I. Advance Pricing Agreements (APAs) 

• The possibility of retroactive application of APAs for a period of up to 5 years is introduced – the extension of validity will depend on the approval of the tax authority competent in  issuing APAs. 
• It is regulated the case in which the taxpayer who is in a tax inspection regarding the taxes  and periods covered by the APAs and who is waiting for the issuance of APAs / the approval  of the retroactive application of the already existing agreement – according to the  amendments introduced the inspection can be suspended until the APAs are resolved. 
• The new provisions will also apply to APAs in the process of being resolved. 

II. Mutual agreement procedure 

• Additions and clarifications are made on the mutual agreement procedure for avoiding double  taxation, so that the affected individuals / legal entities can initiate the procedure even before  the non-compliant taxation with the provisions of tax treaties takes place. 
• The affected taxpayers have the possibility to initiate the procedure within 3 years or within  the term provided in the double taxation convention, computed from the date of  communication of the fiscal-administrative act. If the double taxation convention has a  period shorter than 3 years, it is extended. 
• The mutual agreement procedure in the field of transfer pricing is detailed. 
• Provisions are introduced regarding the obligation of the competent authority in Romania to  initiate the arbitration procedure if the conditions are met. 
• Following the mutual agreement procedure, the administrative-fiscal acts that were the basis  for its initiation can be amended or canceled.  
• The new provisions also apply to the mutual agreement procedure in the process of being  resolved, regardless of their stage.

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For additional details regarding the above, you can contact any member of the Taxhouse team or you can send us an e-mail at office@taxhouse.ro.