Recent trends in transfer pricing at both the local and international levels have brought financial transactions to the fore, which have thus become the object of much more sophisticated approaches by tax authorities focused on qualitative analysis.

Diana Coroaba, Ala Popa, Andrea DumitrescuPhoto: PwC Romania

Following the evolution and how the Romanian tax authorities approach the financial transactions of companies in the non-banking sector, in the recent period, after the introduction of new guidelines in European legislation, we observe dynamics focused especially on aspects related to the essence, economic nature of these transactions, beneficial owner.

Economic substance is a topic increasingly favored by ANAF

Thus, the substance of transactions and their correct classification are often considered by tax authorities as part of tax audits, as well as by authorities of other countries in the context of the Action Plan on Tax Base Erosion and Profit Shifting (BEPS) and subsequent initiatives of this plan.

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The article was signed by Diana Coroaba, Partner, Ala Popa, Senior Manager and Andrea Dumitrescu, Senior Consultant

Article supported by PwC Romania