Noi reguli privind prețurile de transfer: marii contribuabili vor depune anual dosarul la ANAF, iar cerințele de documentare devin mai complexe

The ANAF Order no. 828/2026 introduces significant changes in transfer pricing regulations, including new annual filing requirements for large taxpayers and adjusted materiality thresholds. These rules, effective from 2026, require large taxpayers to submit their transfer pricing documentation within 30 working days after the annual profit tax declaration. The thresholds for services and intangible assets have been lowered, while some thresholds for medium and small taxpayers have increased. The order also demands more detailed information in the documentation, including functional analyses and comparability studies, and emphasizes the importance of timely preparation and integration into financial reporting processes. Companies should start assessing the impact of these changes now to ensure compliance.