Transfer Pricing and Large Companies in Romania
It’s usually only “large companies” that have to prepare transfer pricing documentation in Romania. (Small- and medium-sized companies have to prepare it only at the insistence of auditors.) But just how big is “large?” On October 29, the Romanian National Tax Agency updated the list of large companies that meet its criteria.
Until December 31, 2,940 taxpayers fit the bill by Romania’s large taxpayer office’s standards, but beginning in January 2022, 3,364 will meet the “large-company” criteria—and congratulations, be required to prepare transfer pricing documentation.
There are also transaction level thresholds: Reports on related-party financial transactions must be prepared by large taxpayers only when the associated interests exceed EUR 200,000 ($230,000).
The threshold jumps to EUR 250,000 ($288,000) for service transactions, and for transactions involving tangible assets, the threshold is even higher: EUR 350,000 ($403,000).
Required Documentation
For taxpayers who fit the criteria, transfer pricing documentation—a master file, a local file, and a country-by-country report—must be prepared within 10 days after the annual tax return is due.
Exceptions
And if you’re a taxpayer that doesn’t fall in this group, you’re not entirely off the hook—the tax administration could still request documentation if and when it sees fit.
