Romania transfer pricing documentation guide
March 06, 2008
Ionut Simion and Adrian Luca, of PwC in Bucharest, explain the Romanian authorities’ attitude towards transfer pricing documentation
The Romanian transfer pricing legislation follows the OECD guidelines and requires that transactions between related parties be carried out at market value. In case transfer prices are not set at arm’s length, the Romanian tax authorities have the right to adjust the taxpayers’ revenues and expenses so as to reflect the market value. Profit adjustments on transactions between related parties can be performed only within the domestic statute of limitation period (five years), unless the provisions of the double tax treaties state an alternative period.
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