Transfer Pricing Scheme

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We provide top-notch transfer pricing (TP) documentation. Documentation is prepared by ex-KPMG Managers from Warsaw with many years of experience in the field of transfer pricing across many industries. While the quality is the same as EY, KPMG, PWC, the price of our service is significantly discounted.

Our core service include:

  • Benchmarking analysis
  • Transfer pricing documentation
  • Transaction risk analysis
  • Support for the accounting department

Other TP services:

  • Identification of related entities
  • Audit of applied tax solutions
  • Group and local documentation
  • Transfer pricing policy
  • Investment planning in an aspect of the tax risk related to transfer pricing
  • Representation during a possible tax audit
  • Transfer Pricing training

Who is obliged to prepare Transfer Pricing?

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Romania updated transfer pricing requirements on 1st January 2016. Under the new law TP documentation is required, according to three criteria:

  • size of taxpayer (small, medium, large),
  • materiality thresholds (annual value of inter-company transactions)
  • types of transactions (financial transactions, supply of services, purchases)

1st materiality thresholds for large taxpayers (annual value of inter-company transactions):

  • EUR 200 000 for interest received/paid for financial services;
  • EUR 250 000 for supply/receipt of services;
  • EUR 350 000 for purchase/sales of tangible or intangible assets.

Taxpayers who meet 1st threshold have to prepare a TP file each year.

2nd materiality thresholds for small, medium-sized and large taxpayers (annual value of inter-company transactions of):

  • EUR 50 000 for interest received/paid for financial services;
  • EUR 50 000 for supply/receipt of services;
  • EUR 100 000 for purchases/sales of tangible or intangible assets.

Taxpayers who meet the second set of materiality thresholds have to prepare the TP file only on the request of the Romanian tax authorities during a tax audit.

A TP file is not mandatory for taxpayers that hold an advance pricing agreement (“APA”) issued by the Romanian tax authorities – applies only for the transactions and periods covered by specific APA.

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