Our approach

KPMG in Romania professionals can help companies develop and implement economically supportable transfer prices, document the policies and outcomes, and respond to questions raised by the tax authorities. With our global network providing access to transfer pricing professionals around the world, the Global Transfer Pricing Services practice is well equipped to provide the local experience and global context that multinationals need to thrive in today’s environment.

In the context of the current environment, also as a result of the OECD’s anti BEPS actions, transfer pricing has been significantly transformed. Today’s tax audits in Romania are taking transfer pricing analysis to an unprecedented level. Companies face new challenges, including related to reporting and information sharing.

KPMG in Romania professionals can support companies in the development and implementation of economically sustainable transfer pricing methodologies, document the policies and outcomes, and respond to questions raised by the tax authorities. Transfer pricing policies implemented at group level often need to be localized and intra-group transactions must be supported by documentation and explanations that reflect their practical implementation.

With our global network providing access to transfer pricing professionals around the world, the Global Transfer Pricing Services practice is well prepared to provide both local expertise and the global context needed to help multinationals comply with today’s complex documentation requirements.

We support you in the process of complex analysis and preparing detailed documentation for the intra-group transactions carried out, enabling you to make appropriate strategic decisions in relation to the efficient allocation of resources, in an increasingly complex tax environment marked by budgetary pressures. An effective management of the requirements generated by the OECD anti-BEPS actions requires a clear prioritization of risks, rigorous analysis and constant attention to processes and technology.

The main needs of taxpayers in relation to transfer pricing are the following:

Solid documentation, to help reduce the risk of transfer pricing adjustments;
Where appropriate, application of the Mutual Agreement Procedure (MAP) which limits the risk of double taxation;
Being prepared with explanations, detailed analysis and strong arguments for transfer pricing disputes with the tax authorities, if needed;
Anticipating potential tax audits or tax litigation through periodic analyses of intra-group transactions from a transfer pricing perspective, including comparability studies and detailed, complex and localized economic analyses;
Alignment of the group’s business strategies, as well as its specific operations carried out in Romania, with local tax policies;
Potentially adopting a preventative approach by applying for an Advance Pricing Agreement (APA);
Keeping the administrative burden related to transfer pricing matters low.

What we do

We can assist you in all stages of the transfer pricing management process through such services as:

Planning

Assisting in developing tax policies and transfer pricing mechanisms aligned with economic reality and the long-term objectives of the company, through documentation supported by relevant comparability studies, also taking into account the economic value generated by intra-group transactions policies and in conducting forward-looking tax planning.

Advance Pricing Agreements (APAs) are a particularly useful tool for obtaining prior agreement with the tax authorities in relation to transfer pricing methodology.
Implementation

Providing insightful advice on developing and implementing policies, procedures, controls and systems for managing intra-group transactions, providing transparency and clarity through analysis and documentation.
Controversy

Support in relations with the tax authorities, including assistance with the Mutual Agreement Procedure (MAP), which aims to avoid double taxation through collaborative discussions between the tax authorities of the jurisdictions involved.

Dispute resolution includes assistance in relation to administrative-tax appeals. Together with the KPMG Legal - Toncescu și Asociații team of lawyers who specialize in tax litigation, we provide litigation assistance services in cases which involve transfer pricing adjustments.
Compliance and documentation

Support in meeting strict, transfer pricing documentation requirements, including managing the risks associated with complex regulations and increasingly rigorous tax audits.

A proactive approach, based on risk anticipation, brings long-term added value, both through transfer pricing reviews and through the preparation of transfer pricing reports, together with comparability studies and analyses aligned with local requirements and practices.
Adapting to change

Forward-thinking companies understand that effective global transfer pricing policies must do more than simply enable them to comply with national requirements, as they should also serve as a strategic tool to support investment decisions, improve supply chain structures and enhance global tax planning.
CbyC (Country by Country) reporting

Support in the preparation and submission of the ‘private’ Country-by-Country report for each country, as well as the ‘public’ Country-by-Country report containing corporate tax information, in accordance with the reporting requirements in Romania.

Our insights

Everything you should know about local transfer pricing rules and regulations.

The Fit for Pillar Two series aims to help tax teams of multinational enterprises within the scope of Pillar Two prepare for the upcoming wave of international tax changes by putting theory into practice.