Project Iceberg, launched at the beginning of this year by the Romanian tax authorities, is a giant nationwide operation to be implemented throughout 2019.

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).

Companies can mitigate the risks by having the TP file available before the tax authorities request it.

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.

A company is considered resident if its head office is registered in Romania or has its effective place of management in Romania.