Romania's tax authority signals tighter, more consistent transfer pricing enforcement

Romania's National Agency for Fiscal Administration (ANAF) plans to introduce a unitary, risk-based approach to transfer pricing controls, according to statements by ANAF President Adrian Nica reported by Ziarul Financiar on Friday.

Currently, transfer pricing inspections in Romania are carried out by regional tax offices, often leading to divergent interpretations of the same rules. ANAF has acknowledged that this fragmentation has created uncertainty for investors, particularly for groups with complex intra-group transactions or operations spread across multiple jurisdictions.

Under the new approach, transfer pricing audits would be more centrally coordinated, with standardised methodologies and risk filters applied nationwide. Authorities are expected to place greater emphasis on documentation quality, functional analyses, and economic substantiation, rather than ad-hoc adjustments driven by local practice.

The reform also aligns Romania more closely with OECD transfer pricing guidelines and EU best practices, at a time when tax authorities across Europe are strengthening scrutiny of cross-border transactions, profit allocation, and intra-group financing structures.

ANAF has signalled that companies should already begin preparing for a more structured and data-driven audit environment, particularly in sectors with high related-party activity.

Why it matters:

For investors and multinational operators in Southeast Europe, the shift signals higher compliance expectations but improved predictability in Romania's tax landscape. A more consistent transfer pricing regime reduces regulatory risk over the long term, but may also increase audit intensity and compliance costs, especially for mid-market groups that have historically operated below the radar.