Cost of not-making a transfer pricing file in Romania

According to the Fiscal Procedure Code, if the transfer pricing documentation file is not prepared or presented to the tax authorities, the following fines apply:

- from 12,000 RON to 14,000 RON for companies falling within the category of medium and large taxpayers;  - from 2,000 RON to 3,500 RON for the other companies and for the individuals. ( the daily exchange rates for the Romanian leu, here)

But, in addition to the fine, if the transfer pricing documentation file is not prepared / presented, the tax authorities are entitled to estimate the transfer prices applied by the taxpayer in transactions carried out with related parties. This may lead to additional amounts to be paid to the state budget.