ANAF Order No. 827/2026, published in the Official Journal of Romania No. 543 of 2 July 2026, introduces a revised framework governing the issuance and amendment of Advance Pricing Agreements (“APAs”) in Romania.
The Order updates the procedural rules applicable to APAs and aims to enhance tax certainty for taxpayers engaged in related-party transactions. It also provides additional clarity in relation to the content of APA applications and supporting documentation, while further aligning the Romanian APA framework with OECD Transfer Pricing Guidelines.
Scope of the New Procedure
An APA remains a mechanism through which taxpayers may obtain confirmation from the Romanian tax authorities of the transfer pricing methodology applicable to controlled transactions.
The new procedure applies to APA applications submitted after the entry into force of the Order, while applications filed before this date continue to be governed by the rules applicable at the time of submission.
Importantly, the Order expressly states that its provisions should be interpreted in conjunction with the OECD Transfer Pricing Guidelines. This is particularly relevant for taxpayers seeking APAs covering complex transactions, multi-jurisdictional operating models or bilateral and multilateral arrangements.
