Transfer Pricing

Organisations that span across borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer Pricing is one of the items at the top of the tax priority list for many mid-sized and large businesses. Mazars offers a range of Transfer Pricing solutions, to assist in meeting Romanian regulations.

In recent years, Transfer Pricing has been subject to an increased focus by many Tax Authorities and Transfer Pricing has also become a hot topic in Romania, with public discussions centered around the transactions performed and profits generated by multinational groups in Romania.

Typical areas of Transfer Pricing risks for companies operating in Romania

  • Benchmark studies are the main scrutinized analyses during a Transfer Pricing audit;
  • Group companies that register operating losses or fluctuating operating results have a significant risk of Transfer Pricing adjustments;
  • Intra-group services, as well as royalty transactions, are under the focus of tax audits;
  • The risk analysis carried on by the tax authorities when identifying the companies to be audited;
  • Localisation of Group prepared templates and documentation to the specific requirements of the Romanian Transfer Pricing legislation;
  • Country-by-Country Reporting (CbCR) compliance;

Our approach 

A global, multi-layer approach can bring simplicity to the fast-evolving Transfer Pricing practice. Our global partnership in more than 90 countries provides vital expertise in tracking developments such as new legislation and court/tribunal rulings in each jurisdiction, through direct contact with our Transfer Pricing experts who have the deep industry know-how and the local and international expertise necessary.  

By working in close cooperation with our colleagues from other Mazars offices, we provide solutions that have proven to be efficient for clients in various scopes of activity, as well as with comments regarding the approaches pursued by Romanian Tax Authorities.

We focus to identify the potential encountered risks in case of a Transfer Pricing audit and seek, together with our clients, to identify value-added solutions to mitigate risks to comply with the applicable legal provisions.

Our services: 

  • Preparation of Transfer Pricing reports;
  • Economic analyses and benchmark studies intra-group transactions;
  • Preparation of Transfer Pricing policies and price mechanisms;
  • Assistance during tax audits, as well as drafting tax challenges;
  • Country-by-Country Reporting assistance;
  • Master File preparation;
  • Advance Pricing Agreement (APA) assistance throughout the process of documentation preparation and submission;
  • Mutual Agreement Procedure (MAP);
  • Review of transfer pricing documentation and intra-group agreements;
  • Transfer of functions and value chain analysis.

Our people  

Our team in Romania consists of experienced tax specialists and Transfer Pricing experts with country and sector specific tax and industry know-how, accountants, and economists, which enables us to provide, develop and implement customised Transfer Pricing solutions that fit with our client's commercial and tax strategies.  

Mazars in Romania can provide full service in respect of Transfer Pricing. We have relevant experience and, over time, we provided support to a significant number of companies and multinational groups.