The deadline for submitting the transfer pricing documentation for the fiscal year 2024 is June 25, 2025, the same date by which corporate income tax must be declared and paid, as stipulated by Government Emergency Ordinance No. 153/2020. The tax authorities have consistently confirmed this alignment.
Who is Required to Submit the File?
According to ANAF Order No. 442/2016, large taxpayers are required to prepare the transfer pricing file if they carry out transactions with affiliated entities and if the annual cumulative transaction values (excluding VAT) are equal to or exceed:
- EUR 200,000 for interest from financial services;
- EUR 250,000 for services rendered or received;
- EUR 350,000 for transactions involving tangible or intangible goods.
Exchange rates valid on the last day of the fiscal year are used for conversion.
Who is Exempt?
Companies with an Advance Pricing Agreement (APA) are not required to prepare the file for the covered transactions and periods. The same applies to transactions already subject to ANAF adjustments.
In Case of Tax Inspections
Large taxpayers must provide the file upon request during or outside a tax inspection. Medium and small companies may also be required to prepare the file, but only if explicitly requested during a tax inspection.
File Submission Deadlines
- Large taxpayers: within 10 calendar days from the request, but not earlier than 10 days after the official deadline for file preparation.
- Small and medium taxpayers: between 30 and 60 calendar days, with a one-time extension of up to 30 days upon request.
Risks of Non-Compliance
Failure to provide the file or submitting incomplete documentation may lead the tax authorities to estimate transfer prices and impose significant additional tax liabilities.