On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31 December 2021 and starting from 1 January 2022, the updated list now includes 3,364 taxpayers.
According to the Romanian legislation, transfer pricing requirement for preparing annual transfer pricing files applies for large taxpayers. TP Documentation should be prepared when associated interests of financial related party transactions exceed the EUR 200,000 threshold. In the case of service provisions, the threshold is set at EUR 250,000, while for goods trading it is set at EUR 350,000.
For transactions above the thresholds, large taxpayers should prepare the transfer pricing file no later than 10 days after the annual tax return deadline. If the threshold is not met, transfer pricing requirements are determined individually by the tax administration.
