Transfer Pricing

Transfer pricing is one of the most important international tax issue, which multinational businesses are currently facing.

Transfer pricing solutions, such as effective restructuring, re-pricing or refinancing of transactions can play an important role in assisting your group of companies in maintaining its competitive advantages and meeting shareholders’ financial expectations.

As multinationals consider the borders a matter of little significance for developing their business, tax authorities become increasingly aware of the manner in which transfer prices can affect the taxable base in their country. 

In Romania, since the enactment of the Order 222 / 2008 of the President of the National Tax Agency, regarding the content of the transfer pricing file, the number of transfer pricing audits has grown substantially, and tax inspectors request detailed documentation on all transactions performed with related entities.

Some of the most frequent types of intra-group transactions, for which prices involve a higher degree of subjectivity, thus making them more prone to tax inspectors’ adjustments, are:

  • Inter-company loans granted by the group;
  • Provision of goods and services to/by group entities;
  • Royalties paid for international utilization of group-owned intellectual property;
  • Fees paid for management services received from other tax jurisdictions.

In consideration of the foregoing, it seems more and more advisable for companies to prepare the transfer pricing file in advance, as this represents your only tool for coping with tax audits without major adjustments (and related penalties).

Working in close cooperation with our colleagues of other Mazars offices, we can provide you with solutions that have proved successful with clients active in various industries, as well as insights into the specificities of the approaches adopted by the tax authorities. Our professionals combine technical skills of tax with economic and business management, with a view to helping our clients document their transfer pricing mechanisms and mitigate transfer pricing risks.

Our assistance in the transfer pricing field includes:

  • General information about Romanian transfer pricing regulation;
  • Preparation / Review of transfer pricing documentation;
  • Assessment of tax risks of transfer prices: your customized “transfer pricing diagnosis”;
  • Assistance during tax inspections with regard to transfer pricing aspects;
  • Advance pricing arrangements;
  • Customized trainings.

If you want to know more about our Tranfer pricing services, please read our product sheet and our actual "Transfer Pricing Services" brochure in English:

Transfer Pricing Services_2016.pdf (.pdf - 1.82 MB)