The Romanian tax authorities are scrutinizing intra-group transactions and have recently increased the number of transfer pricing audits. The OECD recently published recommendations as part of its base erosion and profit shifting (BEPS) initiative that greatly expands the documentation burden on multinationals. Together with other countries, Romania has already started the process of adjusting its transfer pricing legislation and compliance requirements to the new international trends.
Success factors for future transfer pricing documentation will require a shift from compliance to strategic risk management. With the drive for transparency here to stay, a need for consistency across all documentation is in the spotlight.