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ARTICLE · 08 JULY 2026

ANAF Order 827/2026: New Advance Pricing Agreement Procedure In Romania And Main Changes

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Order 827/2026 issued by Romania’s National Agency for Fiscal Administration (ANAF) approves a new procedure—including detailed application requirements—for issuing and amending Advance Pricing Agreements (APAs).

RomaniaTax
Roxana Gheorghe
Roxana Gheorghe
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July 2026 – Order 827/2026 issued by Romania’s National Agency for Fiscal Administration (ANAF) approves a new procedure—including detailed application requirements—for issuing and amending Advance Pricing Agreements (APAs). Key changes include the introduction of an optional pre-filing discussion, a formal right to comment on the draft APA, and a rollback mechanism allowing certain past periods to be covered.

1. Structure of the new APA process

Order 827/2026 sets out a clear lifecycle: an optional preliminary discussion; filing of the application; a 60-working-day period for the taxpayer to respond to ANAF's clarification requests (during which the issuance term is suspended); a draft APA issued to the taxpayer for comments (60 working days); and finally issuance or rejection by order of the ANAF president. A taxpayer who disagrees with the APA decision can notify ANAF within 30 days, during which the APA has no legal effect.

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