Advance Pricing Arrangements an Alternative to The Transfer Pricing File. New Developments in Romania

The targeted objectives are to understand the necessity of implementation of the advance pricing arrangement (APA) by the Romanian national tax authority as a technical support in dealing with cross-border transactions between related parties. The paper first identifies the concept of advance pricing arrangement ("APA") together with the adopted OECD framework and then presents the main aspects in respect of the implementation of APA in Romania as a procedure that may provide secure solution for both the taxpayers and tax administration relating to any transaction subject to transfer pricing.