1.  New rules applicable to transfer pricing
2.  Changes regarding advance pricing agreements
3.  Changes regarding the procedure for redirecting corporate income tax
4.  Clarifications regarding the application of the additional 50% deduction for listing on the stock exchange
5.  Simplification of the rules regarding the preparation of the Tax Records Register

1.    New rules applicable to transfer pricing

New rules have been introduced regarding the documentation of transactions carried out with related parties starting from 2026, as well as regarding the preparation and submission of the transfer pricing file.

Among the main new provisions is the obligation of large taxpayers to submit the transfer pricing file annually, electronically, through the Virtual Private Space (SPV), without a prior request from the Romanian tax authorities (ANAF). The file must be submitted within 30 working days from the expiry of the statutory deadline for filing Form 101.

In addition, the value thresholds applicable for the documentation of transactions carried out with related parties have been amended, and a much more detailed methodology has been introduced for conducting the analysis and preparing the transfer pricing file.

More information can be found in the Tax Alert sent on 3 July 2026, available here.

The provisions were published by Order no. 828/2026, Official Gazette no. 543 of July 2, 2026.

2.     Changes regarding advance pricing agreements 

A new procedure regarding the issuance and amendment of advance pricing agreements (APA) has been approved, in the context of the recent changes brought to the transfer pricing legislation.

For this topic as well, more information can be found in the Tax Alert available here.

The provisions were published by Order no. 827/2026, Official Gazette no. 543 of July 2, 2026.

3.    Changes regarding the procedure for redirecting corporate income tax 

The most relevant changes brought to the Procedure regarding the redirection of corporate income tax are as follows:  

• It has been clarified that, also in the situation where it is found that the redirected amount exceeded the amount of corporate income tax or the tax difference that may be redirected, the authorities send the taxpayer a Notification detailing the identified errors and requesting their remediation.
• The rejection of the corporate income tax redirection request is provided for in the situation where, on the date of the verification, it is found that the tax liabilities representing the corporate income tax related to the fiscal year for which the redirection is requested have not been settled. According to the previous provisions, the request was rejected if it was found that the aforementioned tax liabilities had not been settled after the expiry of a 45-day period from the due date.

The provisions were published by Order no. 773/2026, Official Gazette no. 546 of July 2, 2026.

4.    Clarifications regarding the application of the additional 50% deduction for listing on the stock exchange

Considering that, at the beginning of 2026, a new tax incentive was introduced, consisting of an additional deduction, when calculating the fiscal result, amounting to 50% of the expenses related to the process of admission to trading, as well as the expenses related to maintaining the listing, recorded in the first fiscal year, it was necessary to publish a Ministry of Finance Order establishing in detail the types of expenses for which this tax incentive may be applied.

In addition to establishing the eligible expenses, a series of other additional clarifications have also been introduced for taxpayers wishing to apply this new incentive.

The provisions were published by Order no. 804/2026, Official Gazette no. 556 of July 7, 2026.

5.    Simplification of the rules regarding the preparation of the Tax Records Register

In the current context of digitalization, the legislative framework regarding the Tax Records Register has also been updated. Thus, this Order establishes the format and content of the Tax Records Register and allows it to be maintained either in written form or electronically.

It should be noted that the Tax Records Register records, in chronological order, the information underlying the determination of the positive or negative fiscal result and the calculation of corporate income tax included in the declarations regarding corporate income tax payment obligations. It is completed quarterly and/or annually, as well as for any other taxable period, as applicable.

The provisions were published by Order No. 808/2026, Official Gazette No. 556 of 7 July 2026. This Order fully replaced the provisions of Order No. 870/2005.

Disclaimer

The information contained in this newsletter is intended to give you an overview of new legislation; the newsletter does not contain a comprehensive analysis of each topic. For further information on the topics covered please contact us. No responsibility is accepted for decisions or omissions following the use of the content of this newsletter. All Crowe newsletters are available at the address www.crowe.ro.

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