The transfer pricing
file
Preparation and updating under Order 442/2016, with a documented comparability analysis. We have it ready before the tax authority asks for it.
Financial auditorCAFREnvironmental auditorNational RegisterPublic procurement expertAccredited training
Legal framework
BasisOPANAF 442/2016
Large taxpayersPrepared annually
All othersOn request from ANAF
Submission deadlineSet by the tax authority
How it works
Duration3 to 8 weeks
Firm quote24 hours
CoverageAll of Romania
Who needsthis service.
- Companies with related-party transactionsSales, services, loans or royalties within the group.
- Large taxpayersThey must have the file prepared annually, not only on request.
- Companies with shared ownership or managementAffiliation is not only about shareholding.
- Companies already under tax inspectionThe submission window is short and easily missed.
What you receiveat the end of the engagement.
- The complete fileStructured to the requirements of Order 442/2016.
- Comparability analysisWith verifiable sources and a justified pricing method.
- Annual updateThe file stays valid only if it tracks changes within the group.
Frequently asked questionsabout the transfer pricing file.
Who must prepare a transfer pricing file?
Taxpayers carrying out related-party transactions above the thresholds in Order 442/2016. Large taxpayers must have the file prepared annually; all others present it at the tax authority’s request, within the deadline it sets.
What happens if I do not have the file during an inspection?
The tax authority can estimate transfer prices using its own methods, which usually leads to an adjusted tax base and additional tax liabilities. The window given for submission is short, so a file started at that point is rarely finished in time.
How often must the file be updated?
Annually for large taxpayers. For everyone else, whenever new related-party transactions arise or the terms of existing ones change.