Romania Gazettes Ordinance Amending Advance Pricing Agreement, Mutual Agreement Procedure Frameworks

The Romanian Official Gazette July 24 published Ordinance No. 11, amending the Fiscal Procedure Code’s frameworks on advance pricing agreements (APAs) and mutual agreement procedures (MAPs). The ordinance includes measures: 1) allowing APAs to apply retroactively for up to five fiscal years; 2) allowing tax audits to be suspended for up to six months, except for specified APA-related cases; 3) establishing procedures for applying the content of individual tax rulings and APA procedures; 4) establishing MAP enhancements to align with Directive 2017/1852/EU and Convention 90/436/EEC on the elimination of double taxation; and 5) setting a three-year time limit for bringing ...