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For transactions carried out between Romanian companies and their associated foreign entities resident in other member states, the double taxation which might result following the adjustment of profits on one side should, in principle, be eliminated by means of corresponding mirror adjustments, based on the Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises or based on bilateral double taxation treaties. The relevant procedure is yet to be defined in the Romanian legislation in this respect (ie mutual agreement procedure).
Below is a summary of the transfer pricing obligations for Romanian taxpayers:
authors: Theodor Artenie and Anamaria Tocaci