Romania Tax Agency Issues Draft Order on Advance Pricing Agreement Procedures, Documentation Requirements

The Romanian National Agency for Fiscal Administration June 5 issued a draft order to approve the procedures and documentation requirements for advance pricing agreements (APAs). The draft order includes measures to: 1) establish procedures for issuing, modifying, extending, revising, and cancelling APAs for transactions between affiliated persons, supplemented by OECD transfer pricing guidelines; 2) allow taxpayers to request preliminary discussions and submit additional information during the review; 3) set rejection conditions for incomplete documentation, late amendment requests, and inaccurate information; 4) define eligibility to extend agreements to previous periods based on similar transactions, parties, and contractual terms; 5) specify agreement ...