The legislation updates rules for Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs)
Romania’s government published Emergency Ordinance 11/2025 (GEO 11/2025) in the Official Gazette No. 695 on 24 July 2025, to amend the Fiscal Procedure Code approved through Law 207/2015.
This legislation introduces changes to the Advance Price Agreement (APA) and Mutual Agreement Procedure (MAP), including ongoing cases.
The Ordinance allows taxpayers to request retroactive application of an APA for up to five years before the filing year, subject to tax authority approval. In such cases, ongoing tax inspections may be suspended until the APA is issued.
The amendments to the Mutual Agreement Procedure (MAP) align national law with Article 25 of the OECD Model Tax Convention and introduce procedural rules similar to those in EU Directive 2017/1852 on tax dispute resolution.