ANAF Order No. 828/2026 introduces significant changes in the field of transfer pricing.
However, with the exception of large taxpayers, the preparation of the transfer pricing file remains mandatory only if it is expressly requested as part of a tax audit.

The main provisions are:

• Materiality thresholds (EUR/individual transaction/related party):

Transaction type Large taxpayers Small and medium-sized taxpayers
Services 100.000 50.000
Interest 200.000 100.000
Intangible assets / royalties 250.000 150.000
Tangible assets 350.000 200.000

 

• Large taxpayers must submit the transfer pricing files via the Virtual Private Space (SPV) within 30 days from the deadline for filing the corporate income tax return.
• Small and medium-sized taxpayers are required to submit the transfer pricing file only if expressly requested, within 30–60 days from the date of the request, with the possibility of requesting a single extension of up to 30 days.
• The content of the transfer pricing file has been expanded, and a reporting annex has been introduced, standardizing the presentation of related-party transactions and year-end adjustments.