Transfer Pricing Alerts

Significant legislative amendments regarding transfer pricing 

ANAF published the Order no. 442/2016 regarding the values of the transactions, the deadline for the preparation, the content and conditions for the request of the transfer pricing file and the procedure of the adjustment / estimation of the transfer prices. 

This Order brings significant amendments regarding the legislation applicable in the transfer pricing area. 

The main legislative amendment is represented by the introduction of the annual obligation for the preparation of the transfer pricing file applicable to large taxpayers which carry out intra-group transactions exceeding certain thresholds. The deadline for the preparation is the legal deadline set for the submission of the annual corporate income tax return. These provisions apply to the intra-group transactions carried out starting with the year 2016.