Romania has published updated transfer pricing regulations that introduce stricter documentation requirements and align domestic rules more closely with the OECD Transfer Pricing Guidelines. Order No. 828/2026, published in the Official Gazette on July 2, replaces Order No. 442/2016 and will apply to transactions with affiliated parties carried out from 2026 onwards.

The new framework introduces revised rules on transaction thresholds, documentation deadlines, the content of transfer pricing files, the conditions under which tax authorities may request them, and the procedures for adjusting or estimating transfer prices, Ziarul Financiar reported.

One of the most significant changes concerns large taxpayers, who will be required to prepare transfer pricing documentation annually by the deadline for filing the corporate income tax return. The documentation must then be submitted electronically through Romania's Virtual Private Space (SPV) platform within 30 working days.

The order also formally aligns Romanian legislation with the OECD Transfer Pricing Guidelines by incorporating concepts such as the Master File, detailed functional analysis, the use of local and regional comparables, and documentation of comparability adjustments.

For companies that are part of multinational groups, the new framework represents a significant shift, as transfer pricing documentation will become an annual compliance obligation rather than a process primarily associated with tax audits.

iulian@romania-insider.com

(Photo source: Alexandru Marinescu/Dreamstime.com)