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Romania transfer pricing documentation guide

March 01, 2010

Ionut Simion and Blanca Kovari, of PwC in Bucharest, explain the Romanian tax authorities’ attitude towards transfer pricing documentation.

The Romanian transfer pricing legislation follows the OECD transfer pricing 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)..

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