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ARTICLE · 06 JULY 2026

New Romanian Transfer Pricing Documentation Rules — ANAF Order 828/2026

Romania's tax authority ANAF has issued Order 828/2026, fundamentally restructuring transfer pricing documentation requirements to align with OECD guidelines. The new framework introduces mandatory electronic filing for large taxpayers, per-counterparty transaction thresholds, and significantly expanded documentation standards that will reshape compliance obligations for multinational enterprises operating in Romania.

RomaniaTax

July 2026 – ANAF Order 828/2026 replaces the transfer pricing (TP) documentation framework that had applied under Order 442/2016. The stated purpose is to align Romanian documentation requirements with the 2022 edition of the OECD Transfer Pricing Guidelines and the outcomes of the BEPS project.

The new rules bring five structural changes detailed below:

  • a mandatory annual electronic filing of the TP documentation for large taxpayers;
  • significance thresholds tested per counterparty and per transaction category rather than in aggregate;
  • materially expanded and more prescriptive documentation content;
  • a standardised, transparent comparability study delivered in Excel;
  • a standardised list of intra-group transactions, delivered in Excel and PDF.

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