Transfer Pricing - Mazars - Romania
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Transfer Pricing
Transfer prices, i.e. the prices at which goods and services are sold between associated enterprises, are acknowledged to be the most important international tax issue facing multinational businesses.
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.
But, at the same time, while multinationals see the borders as irrelevant for developing their business, tax authorities become increasingly aware of the manner in which transfer prices can affect the taxable base in their country. We are thus facing an increasing enforcement of existing tax regulations, particularly from a documentation perspective.
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 have acquired broad and thorough knowledge of the solutions that have proved successful with clients active in various industries, as well as insights into the specificities of the approaches adopted by tax authorities. Our professionals combine technical skills of tax with economic and business management, with a view to helping our clients to 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.
For any supplementary information regarding our related services, please open the files below:
- Mazars_Insert_TransferPricing_RO-2011.pdf (.pdf - 1.06 MB)
- Mazars_Insert_TransferPricing_EN_2011.pdf (.pdf - 1.06 MB)
- Mazars_Insert_TransferPricing_FR_2011.pdf (.pdf - 1.21 MB)
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