Companies that carry out transactions with related parties often face financial, tax and legal obstacles that impact their daily business activities. Therefore, in order to comply with domestic and international Transfer Pricing regulations and to ensure a smooth transfer of goods and services among related parties, it is necessary to have a sound and coherent Transfer Pricing policy.
General Transfer Pricing rules have been implemented in Romanian legislation in 2003 via the Tax Code, mentioning arm´s length principle and the specific methods provided by OECD in order to determine the market value of transactions between related parties.
Currently, Romanian companies are obliged to keep Transfer Pricing documentation for both cross-border and domestic transactions. According to the Romanian tax legislation, all related parties are obliged to prove the method applied for setting the prices of controlled transactions (domestic or cross-border) between related parties and keep a relevant documentation justifying this method.
In recent years, the number of tax inspections on Transfer Pricing rapidly increased, that is why we recommend to focus on this area and especially on preparation of the proper Transfer Pricing documentation.
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