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Which companies are required to produce a transfer pricing file annually?

In order to document compliance with the principle of market value, the transfer pricing file must be prepared annually by the big taxpayers.

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According to legal provisions, in order to document compliance with the market value principle, the annual transfer pricing file is required for the contributions of the category of big taxpayers, established by order of the President of the national Agency for tax Administration, which carry out transactions with affiliated persons of an annual total value, calculated by adding together the value of transactions made with all related persons, excluding VAT, of any of the following materiality thresholds:

  • EUR 200 000, in the case of interest received/paid for financial services, calculated at the exchange rate notified by the national Bank of Romania for the last day of the fiscal year;
  • EUR 250 000, in the case of transactions relating to supplies of services received/supplied, calculated at the exchange rate notified by the national Bank of Romania, for the last day of the fiscal year;
  • EUR 350 000, in the case of transactions relating to purchases/sales of tangible or intangible goods, calculated at the exchange rate notified by the national Bank of Romania as valid for the last day of the fiscal year.