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Romania: Amendments to rules for advance pricing agreements (APAs) and mutual agreement procedure (MAP)

APAs may apply retroactively for up to five years.

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october 14, 2025

The Romanian government on July 24, 2025, issued Emergency Ordinance 11 (GEO 11/2025), allowing advance pricing agreements (APA) to apply retroactively for up to five years, pending tax authority approval.

The government also implemented changes to the mutual agreement procedure (MAP) to align with OECD and EU standards, enable initiation by affected persons, set a three-year deadline, and require settlement decisions contingent on waiving legal challenges.


For more information, contact a KPMG tax professional in Romania:

Alecu Teodora | talecu@kpmg.com

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