ANAF Order No. 828/2026, published in the Official Journal of Romania No. 543 of 2 July 2026, introduces significant amendments to the Romanian transfer pricing (“TP”) documentation framework. The new rules revise the transaction value thresholds, documentation deadlines, content requirements and conditions under which a transfer pricing file may be requested by the tax authorities. The Order also updates the procedure for transfer pricing adjustments and estimations.
A key development is the introduction of a requirement for large taxpayers to submit their transfer pricing documentation electronically through the Romanian Virtual Private Space (“SPV”), provided that transactions with related parties exceed the thresholds established in legislation.
The annual documentation requirement for large taxpayers applies to related-party transactions carried out starting from the fiscal year 2026, while the new procedural framework will generally apply to tax administration procedures initiated after 1 January 2027.
Given these changes, taxpayers should consider reviewing and assessing their intra-group transactions carried out from fiscal year 2026 onwards.
