Advance pricing agreement

“The advance pricing agreement is the administrative document issued by the central fiscal body in order to settle a request of the taxpayer/contributor, for setting the conditions and manners in which the transfer pricing is to be determined, during a fixed period, in case of transactions carried out with affiliated persons, as defined in the Fiscal Code. Future transactions which are object of the advance pricing agreement are estimated depending on the date the request is submitted. The taxpayer/contributor will be able to ask an advance pricing agreement also to determine the fiscal result attributable to a permanent office”

  • The advance pricing agreement is an agreement concluded between tax authorities and taxpayer, by which the latter provides the trustworthiness of the market character of the transfer pricing used for intra-group transactions, for future periods. Therefore, in order to comply with the provisions regarding transfer pricing in Romania, a taxpayer can choose to voluntarily submit the intra-group transactions carried out, as well as the methodology for the transfer pricing used in relation with the affiliated persons, to the tax authorities by an advance pricing agreement;
  • We provide assistance to clients for preparing the documentation necessary to submit an application in order to obtain an advance pricing agreement;
  • We provide assistance to clients for obtaining advance pricing agreements by setting up meetings with tax authorities and providing the technical arguments.

Want to know more?