Evoluția analizei de risc în materia prețurilor de transfer: Raportul ANAF semestrul I 2026 relevă progrese, dar și aspecte care necesită clarificări

The ANAF report for the first half of 2026 shows advancements in transfer pricing analysis but highlights areas needing clarification. While the agency has aligned its regulations with OECD standards and improved data access, the practical application of this data remains unclear. New regulations have been introduced, yet transparency in procedures is lacking, which could lead to inconsistencies in tax inspections. The report also notes the use of algorithms for risk assessment, but details on the criteria used are limited. Despite progress in mutual agreement procedures and advance pricing agreements, the report does not provide comprehensive results or timelines. Overall, while there are improvements, significant gaps in information and clarity persist.