August 2025 - The Romanian tax authorities have recently enacted legislative changes concerning advance pricing agreements (APAs), with the aim of enhancing the regulatory framework and supporting tax compliance.
Key amendments include:
- The introduction of the possibility to request the issuance of an APA for historical transactions, with retroactive application of up to five years, subject to conditions that will be detailed in secondary legislation.
- The option for the tax authorities to suspend tax audits for periods covered by submitted APA requests, in order to prioritise their resolution.
- A revision of the mutual agreement procedure for the avoidance of double taxation, aimed at facilitating the resolution of international tax disputes.
The primary objective of these changes is to enhance predictability and transparency in the relationship between taxpayers and the tax authorities by encouraging voluntary compliance and supporting the business environment. At the same time, the amendments seek to align Romania's regulatory framework with OECD and EU standards, thereby reinforcing the country's credibility as a responsible tax partner.
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