Transfer Pricing

A global view on a business-critical, fast-evolving issue

Organisations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on and business units. We offer a range of solutions for transfer pricing management so you can ensure compliance with local regulations.

Our approach

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your tax positions.

Transfer pricing in Romania

The establishment and documentation of the transfer pricing represents one of the most important matters of taxation which the Romanian and multinational groups must currently face. In Romania, the number of tax inspections which have aimed also the verification of the compliance with the legislation regarding the transfer pricing increased significantly in the last 3-4 years. Considering that the legislation is in force since 2008, the authorities consider that the transfer pricing file is no longer a new element and the controls for this purpose are a constant element of all fiscal inspections for those taxpayers which are carrying out transactions with affiliated persons.

The subject of taxation of the multinational groups is one of topical importance in the Romanian public area, reason for which the tax authorities are trying, more and more often, to verify the compliance of the Romanian companies, which are part of these groups, with the legislation in force.

In case of a control, the risk lies in the possible adjustment of the pricing used in the relation with affiliated companies, adjustment by which either the income is increased, or the expenses made by the company in Romania are deducted, in order to increase the taxable profit.

Our services

  • Strategic advice on all aspects of transfer pricing
  • Master file, local file and country by country reporting
  • Tax audits, mutual agreement procedures
  • Value chain analysis and transformation
  • Economic analyses, including commercial benchmarks, loan benchmarks, and license benchmarks
  • Cash pools and other integrated group wide financing systems
  • Transfer of functions, valuation of transfer packages, exit taxation
  • Valuation of hard to value intangibles

Our people 

Our team consists of experienced tax specialists and transfer pricing experts with country and sector specific tax and industry knowhow, that provide, develop and implement customised transfer pricing solutions that fit your commercial and tax strategies.