Romania: Amendments to transfer pricing documentation rules
Significant amendments to the Romanian transfer pricing documentation framework
Romania’s National Agency for Fiscal Administration (ANAF) Order No. 828/2026—published in the Official Journal of Romania (No. 543 dated July 2, 2026)—introduces significant amendments to the Romanian transfer pricing documentation framework.
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, 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 January 1, 2027.
Read a July 2026 report prepared by the KPMG member firm in Romania
For more information, contact a KPMG tax professional in Romania:
Vlad Craciun | vcraciun@kpmg.com