The entry into force of OUG No. 8/2026 marks an important step in consolidating Romania’s fiscal calendar by definitively setting June 25 as the single deadline for the declaration and payment of corporate income tax, as well as for the completion of transfer pricing documentation. The measure removes previous uncertainties regarding a potential return to the March 25 deadline and establishes a more predictable framework for taxpayers.
Alignment of tax and documentation obligations
The new regulation continues the approach introduced by OUG No. 153/2020, synchronizing tax reporting obligations with the documentation of intra-group transactions. Thus, taxpayers must finalize the transfer pricing file simultaneously with the calculation and filing of corporate income tax, reducing the risk of inconsistencies or subsequent adjustments.
Large taxpayers – strict annual obligations
According to Order No. 442/2016 issued by ANAF, large taxpayers exceeding the materiality thresholds must prepare the transfer pricing file annually by June 25:
• €200,000 – financial services
• €250,000 – services
• €350,000 – transactions with goods (tangible/intangible)
The documentation must be available by the deadline and may be requested by the authorities even outside a tax audit, with a submission deadline of up to 10 calendar days.
Small and medium taxpayers – reactive approach
For this category, the obligation arises only upon request by the tax authorities. The thresholds are lower:
• €50,000 – services
• €100,000 – goods
The preparation timeframe ranges between 30 and 60 days, with the possibility of a single 30-day extension.