Article also available in / Articol disponibil și în limba:
Română (Romanian)
From 2027: large taxpayers may have to submit the transfer pricing documentation annually, in Romanian language, in an easier-to-review format for tax authorities
published on 15 June 2026
On 10 June 2026, Romanian Tax Auhorities published a draft order regarding the procedure for preparing and submitting the transfer pricing documentation. This order is set to replace current transfer pricing legislation.
If adopted in its current form, the order would apply starting 1 January 2027.
The proposed changes are numerous and nuanced.
However, there are several key aspects that large taxpayers should focus on. These changes affect when the documentation is prepared, how it is submitted, the form in which it sent to the Romanian Tax Authorities, and how the consultant preparing it should be selected.
The transfer pricing documentation would no longer be merely a document prepared and kept for the moment when the Romanian Tax Authorities requests it. It would have to be submitted annually, in Romanian language, and once submitted, it becomes the official version assumed by the taxpayer.
The transfer pricing documentation would have to be prepared and submitted annually, not only provided upon request
One of the most important changes is the introduction of an annual submission obligation for large taxpayers.
Until now, large taxpayers were required to prepare the transfer pricing documentation, but in practice they mainly provided it upon request from the tax authority. This allowed taxpayers to review the documentation multiple times until it was in practice audited. The documentation could still be updated, checked or adjusted before being formally submitted to Romanian Tax Authorities.
The draft order changes this logic.
The transfer pricing file would have to be submitted annually, in electronic format, through the Virtual Private Space, under the signature of the legal representative or authorised representative, within no more than 30 working days after the deadline for submitting the corporate income tax return.
For taxpayers, this means one simple thing: the file can no longer be treated as a document finalised only when a request is received. It has to be prepared in advance. Data must be collected earlier. And the submitted version must be reliable, consistent and properly reviewed.
The threshold for intra-group services would decrease significantly
Another important change concerns the threshold applicable to transactions involving intra-group service acquisitions.
For large taxpayers, this threshold would decrease from EUR 250,000 to EUR 100,000. In practice, this means that more intra-group services transactions may fall within the scope of the transfer pricing file documentation requirements.
As a result of the lower threshold, the transfer pricing documentation may become more extensive, and taxpayers will have to monitor more closely which transactions fall within the documentation obligation.
In other words, it is not only the submission deadline that would change. The volume of information that needs to be prepared, reviewed and included in the file may also increase.
Also, companies that previously did not exceed the €250,000 threshold for intra-group service transactions but did exceed the €100,000 threshold will now also be required to prepare a transfer pricing documentation.
Romanian language and electronic format become essential
The transfer pricing documentation must be submitted in Romanian language.
For taxpayers working with documentation prepared in English, this change matters significantly. Until now, many companies prepared the transfer pricing documentation in English at group level, then translated or adapted it when needed.
Now, the timeframe becomes shorter. If the documentation must be submitted annually, within a deadline linked to the corporate income tax return, translation can no longer be treated as a secondary step left until the end.
Translation takes time. Adaptation takes even more. And a documentation translated quickly, without a local tax review, may appear complete in form but weak in substance.
This is why the issue is not only the language. The real question is whether the documentation properly explains the transactions of the Romanian taxpayer, whether it complies with local requirements, and whether Romanian Tax Authorities can follow the analysis.
At the same time, the transfer pricing documentation becomes easier for the tax authorities to review. It can no longer be submitted merely as a static PDF. The appendices, tables and relevant information must be provided in a format that allows the data to be checked.
This will make the review faster. Excel files, formulas and calculations can quickly reveal errors, inconsistencies or conclusions that are not supported by the data.
A well-prepared transfer pricing documentation will withstand this type of review more easily. A superficial transfer pricing documentation will be more exposed.
Which taxpayers are most affected?
The updates will not have the same effect on all large taxpayers. The impact will be greater in cases where documentation was prepared late, was adopted almost entirely from the group level, or was not sufficiently adapted to local conditions.
➤ The legislation updates will not have the same impact on all large taxpayers. The impact will be higher where taxpayers were late with the preparation of the documentation in the past. Now, they will have to prioritise the preparation of the transfer pricing documentation.
➤ Second, large taxpayers that traditionally prepared transfer pricing documentation in English language at headquarter level, will now have to make sure it is fully compliant with Romanian Tax legislation and Romanian Tax Authorities expectations, each year, year after year. Insufficiently adapted / localised documentation now may do more damage than good.
➤ Third, large taxpayers that are not up to date with their transfer pricing documentation will also be affected. If the documentation must be submitted annually, delays become harder to recover. The process must start earlier, not be pushed towards the end of the deadline.
➤ Fourth, large taxpayers preparing the transfer pricing documentation only with internal resources may also feel the impact. The internal team knows the business. However, a transfer pricing documentation also requires methodology, experience in tax audits, comparability analysis and the ability to build a tax argument that can be sustained.
➤ Last but not least, companies that previously did not exceed the €250,000 threshold for intra-group service transactions but did exceed the €100,000 threshold will now also be required to prepare a transfer pricing documentation.
What should be monitored in practice
For large taxpayers, the key issue is not only meeting a deadline. The real issue is preparing documentation that can be reviewed, explained and supported to the Romanian Tax Authorities.
Data must be collected earlier, and contracts, invoices, transaction descriptions, service justifications, calculations and appendices should be reviewed in advance.
In addition, the documentation must be prepared in Romanian language and adapted to local requirements. Group-level documentation may remain a useful starting point, but the documentation submitted in Romania should reflect the situation of the Romanian taxpayer and be easy for Romanian Tax Authorities to follow.
This is why the team preparing the documentation becomes more important. In many cases, involving a local consultant may be useful, as they understand Romanian Tax Authorities’ practice, the Romanian documentation requirements and how the tax argument should be built in order to be supported during a potential tax audit.
The format of the transfer pricing documentation becomes just as important as the argument itself. If the appendices and tables are submitted in a format that allows fast audit, any inconsistency may become visible much faster.
This is a change in approach, not only a procedural change
The transfer pricing documentation can no longer be treated as documentation prepared merely to tick a compliance box. Large taxpayers will have to allocate real time to this process, carefully review the information included and be more rigorous when selecting the team preparing the transfer pricing documentation.
Once submitted, the documentation becomes the official version assumed for the relevant period. And in a future tax audit, this is precisely the version that will be reviewed, explained and discussed with the tax authorities.
Therefore, the objective is not only for the documentation to be sound at the time of submission, but also for it to remain coherent and defensible several years later. The approaches included in the transfer pricing documentation should be designed from the outset to be strategic and sustainable in the long term
ATIPIC Solutions is a 100% transfer pricing dedicated and specialized transfer pricing firm with a culture centered around effectiveness of building reliable transfer pricing documentations though automations and innovation. We work with companies that have as their ERP of choice SAP, Oracle, Microsoft or Scala and we are recognized in the World TP / International Tax Review Rankings.
If you found this article useful, you may likely find all our other articles that we can send straight to your inbox… so we offer you the possibility to request a free of charge complimentary subscription to our newsletter if you submit the form below:
