The National Agency for Tax Administration (NAF) recently announced in a press release that “structures carrying out the duties of fiscal inspections conducted 555 fiscal audits and unannounced audits of large taxpayers, as well as 128 unannounced audits of companies with recurring losses. . (…) These operations were initiated as a result of the fiscal risk analysis.” Periodically, ANAF publishes the following announcements, and you may have wondered:

– How are companies selected for tax audits and what sources of information are considered to establish tax risk from the point of view of transfer pricing?

– What information presented in the financial and accounting documents submitted to ANAF by each company raises questions and generates either unexpected control or, more recently, documentary confirmation?

– What is the risk for the company in such areas of fiscal risk and what exactly causes the preliminary control mentioned in the ANAF press release?

– How should the company position itself, reactively, after the start of control, or proactively, in order to understand from the very beginning which areas of influence and how it can adequately prepare?

The experience of recent tax audits shows the repetition of the approaches of tax authorities, especially in the field of transfer pricing, both initially, at the stage of preliminary selection (at the level of sudden control or documentary inspection), and later, at the stage of conclusions (actual fiscal audit).

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The article was signed by Monika Todose, Director, Livia Teodoru, Director and Anastasia Derevyanchyna, Senior Manager

Article supported by PwC Romania