The Romanian Government published Orders at the end of 2015 regarding binding tax rulings and advance pricing agreement (APAs).
Under the provisions on binding tax rulings the tax situation that is to be the subject of the ruling must be in the future, subsequent to the submission of the request for an advance binding tax ruling. The tax treatment established through the binding tax ruling is applicable as of the date when the future operation is carried out.
The tax authorities may request additional information or documents, as well as clarifications for the purpose of the requested binding tax ruling. If additional information is requested the deadline for the issuance of the binding tax ruling is suspended and extended for the period between the date of the request and the date when the additional information is obtained.
In the case of advance pricing agreement (APAs), the relevant order no. 3735 provides guidance on procedural details concerning the issuing and modifying of APAs, the content of the request regarding the APA, the necessary documentation and the method of submission.
