Romania Transfer Pricing Policy

Email: prg4ww@evershinecpa.com
The Engaging Manager from Headquarter
Ms. Anna Wang, Speak Romanian English, and Chinese.
skype: burlinna

TP-Q-10

Why kinds of scenario will be adopted TP policy? What is relevance between DTA and TP policy?

TP-A-10

When Romania Tax entity would like to pay out whatever Business profits, Royalty, Technical Services fees, Interests, Trading amount etc., it will adopt DTA tax rate. Its judge criteria, please see the Romania Treaty Page.

But if want to verify the above-mentioned amount if reasonable, will adopt Romania TP Policy.

TP-Q-20:  

What are the scenarios in Romania, that a Wholly Foreign-Owned Entity (WFOE) exempted from compliance of Transfer Pricing (TP) declaration and TP documentation?

TP-A-20:

Exemptions for TP documentation are provided only for materiality reasons, as follows:

For transactions below certain thresholds (50,000 euro for interests and services and EUR 100,000 for goods) there is an exemption for TP File documentation obligations.

TP-Q-30:  

What are the scenarios in Romania, that a Wholly Foreign-Owned Entity (WFOE) required to submit TP declaration to country’s tax bureau? What is the name of the TP declaration form?

TP-A-30:

No specific transfer pricing declaration returns is required.

TP-Q-40:  

What are the scenarios in Romania, that a Wholly Foreign-Owned Entity (WFOE) required to submit TP declaration and TP documentation to country’s tax bureau? What is the name of the TP declaration form and TP documentation form?

TP-A-40:

Local and Master File –
The annual value of related-party transactions exceeds 200,000 euros of interest income or 250,000 euros of suppliers of services or 350,000 euros of supplies of goods.

Country-by-country (CbC) Report –
Multinational enterprise (MNE) groups with consolidated turnover of at least 750,000,000 euros in the preceding fiscal year.

Romania TRANSFER PRICING for professionals

Overview

Romanian transfer pricing rules apply to intra group transactions performed either between domestic entities or between a Romanian and a foreign entity.

The national transfer pricing legislation follows the OECD Guidelines and requires that all transactions between related parties be carried out at market value (i.e., at arm’s length value) without exception.

All Romanian taxpayers performing intragroup transactions are required to prepare and provide, upon the formal request of tax authorities, the transfer pricing file (usually during a tax inspection).

Romania follows the OECD Transfer Pricing Guidelines and the Code of Conduct on transfer pricing documentation with regard to its transfer pricing documentation requirements.

Related Parties

1. One entity holds directly or indirectly a minimum of 25% of shares or voting rights in the other entity or it effectively controls the other entity, and
2. One entity holds directly or indirectly a minimum of 25% of shares in the 2 entities.

Acceptable Transfer Pricing method

*Comparable Uncontrolled price method (CUP)

*Resale price method (RPM)

*Cost-plus method (CPM)

*Profit split method (PSM)

*Transactional net margin method (TNMM)

Due dates and respective threshold:

Please be aware of below Warning:

The above contents are digested by Evershine R&D and Education Center in October 2021.
Regulations might be changed as time goes forward and different scenarios will adopt different options.
Before choosing options, please contact us or consult with your trusted professionals in this area.

Contact Us

Bucharest Evershine BPO Service Limited Corp.
Email: prg4ww@evershinecpa.com
The Engaging Manager from Headquarter
Ms. Anna Wang, Speak Romanian, English and Chinese.
skype: burlinna

or
For how to exchange data files between your Finance Accounting System and Evershine Cloud Accounting Information System, please send an email to HQ4buh@evershinecpa.com
Dale Chen, Principal Partner/CPA in Taiwan+China+UK will be accountable for your case.
LinkedIn address: Dale Chen

Additional Information

Evershine CPAs Firm Headquarters
6th Floor 378 Chang Chun Rd., Taipei City, Taiwan ROC
Partner Kerry Chen, USA Graduate School and a well-English speaker
Tel No.: +886-2-27170515 ext. 105
Mobile: +886-939357000
Email: kerrychen@evershinecpa.com
Skype: oklahomekerry

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(version: 2022/03)

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