Romania Transfer Pricing Documentation Requirements
Romania requires a transfer pricing file from large taxpayers whose related-party transactions exceed set annual thresholds. The rules prescribe a strict sequence for selecting comparables, beginning with local data, and the principal exposure lies less in the fixed penalty than in the risk of an adjustment challenging the benchmark.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Transfer pricing file
Required | Large taxpayers above the annual transaction thresholds (e.g. EUR 200,000 for interest) | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | RO | Yes (around EUR 3,000 to EUR 3,500; adjustment risk) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
Romania requires a transfer pricing file from large taxpayers whose related-party transactions, aggregated across all related parties and excluding VAT, reach the significance thresholds set by the relevant order of the fiscal administration. Those thresholds are expressed by transaction category, beginning at EUR 200,000 for interest and rising for other categories. The file is held available by the return filing date and produced on request during an audit.
Distinctive features of the Romanian regime
Two features distinguish the Romanian regime. The first is the prescribed sequence for comparables. The rules require the territorial criteria for a benchmarking analysis to be applied in a fixed order, moving from local, to European Union, to pan-European, and finally to international data, with the absence of local comparables a point the tax authorities investigate closely before foreign comparables are accepted. The second is where the real exposure sits. The fixed fine for an incomplete file is modest, around EUR 3,000 to EUR 3,500, but the larger risk is a transfer pricing adjustment in which the authority challenges the benchmark study itself. There is no published safe harbour and no transfer-pricing-specific return.
Benchmarking and comparables
The territorial criteria are applied in the prescribed sequence of local, European Union, pan-European, and international, with foreign comparables accepted only where local comparables are shown to be unavailable. There is a preference for single-year testing, with multi-year analysis acceptable where properly justified. A fresh benchmarking search is required periodically, with a roll-forward or financial update of a prior study acceptable for a defined period depending on the circumstances. There is no specific transfer pricing limitation period: the general rule permits review for five years, extended to ten years in cases of evasion or fraud.
Frequently asked questions
In what order must Romanian comparables be selected?
The territorial criteria are applied in a prescribed sequence: local first, then European Union, then pan-European, and finally international. Foreign comparables are accepted only where local comparables are shown to be unavailable.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.