We would like to draw your attention to a press article offering official data on the Romanian Tax Administration (ANAF, in Romanian) activity regarding transfer pricing.

Below, you can see the highlights:
• During the 2010 – 2013 period, there were 402 audits requiring the transfer pricing documentation file.
• Compared to the 2010 – 2012 period, the audits from 2013 represent roughly 15% of the tax audits in which the supervisory body ordered the elaboration of the transfer pricing documentation file.
• In 2013, the maximal transfer pricing adjustment was performed with about 72% higher than the adjustment made in the previous year, 2012.
• The amount of the additional amounts (income tax, penalties and late payment penalties) is around RON 48 million, in 2010 – 2013.
• Regarding the reference period, the fiscal loss of the audited taxpayers (including the transfer pricing documentation file) has been reduced by about RON 450 million.
• All tax inspectors of the ANAF tax inspection apparatus are responsible for examining the transfer pricing documentation file by requesting it.

Even though the balance statement does not seem spectacular for the public, it reflects an alignment of the ANAF with the worldwide trend of perceiving the transfer pricing as a top tax priority.
In our March TPS Express newsletter we will return with new information for your Transfer Pricing Safety.