TTP supports clients across the full transfer pricing lifecycle: documentation, benchmarking, audit support, dispute prevention through APA and dispute resolution through MAP.
Transfer pricing should be aligned with the broader tax strategy of the business. Weak documentation, inconsistent tax treatment or unprepared audit responses can create significant tax leakage and dispute risk.
Transfer pricing is not only about preparing a file. It is about understanding the substance of related-party transactions, documenting the arm's length position, managing audit risks and selecting the appropriate approach when uncertainty or disputes arise.
TTP assists clients with documentation, benchmarking, intra-group transaction reviews, tax audit support, Advance Pricing Agreements and Mutual Agreement Procedures.
Related-party transactions often represent one of the most significant tax risk areas for companies operating in Romania. Management fees, services, royalties, financing, guarantees and business restructurings can affect not only transfer pricing documentation, but also corporate tax deductibility, withholding tax, VAT, accounting treatment and audit exposure.
TTP integrates transfer pricing work with the broader tax strategy of the company, helping clients avoid fragmented positions and prepare coherent, defensible documentation.
Preparation and review of transfer pricing files, including functional analyses, economic analyses, transaction descriptions and documentation of related-party arrangements.
Selection and analysis of comparable companies or transactions to support the arm's length nature of intra-group pricing.
Review of functions performed, assets used and risks assumed by related parties, aligned with the economic substance of the business.
Analysis of management fees, shared services, cost allocations, service benefit tests and supporting documentation.
Review of intra-group loans, interest rates, guarantees, cash pooling and financing arrangements from a transfer pricing perspective.
Analysis of royalties, licensing arrangements, intellectual property, DEMPE considerations and supporting documentation.
Support in analysing transfer pricing implications of reorganisations, changes in business models and transfers of functions, assets or risks.
Assistance during transfer pricing audits, including review of tax authority requests, preparation of technical responses, risk analysis and support in defending the transfer pricing position.
Support in assessing, preparing and managing APA processes as a dispute prevention mechanism for transfer pricing matters.
Support in assessing and managing MAP cases as a dispute resolution mechanism in situations involving double taxation or transfer pricing adjustments with cross-border impact.
Transfer pricing risks can be addressed at different stages. In some cases, robust documentation and audit readiness may be sufficient. In other cases, companies may need to consider APA or MAP.
APA is a dispute prevention mechanism. It may provide advance certainty on the transfer pricing methodology applicable to specific transactions.
MAP is a dispute resolution mechanism. It may be relevant when a transfer pricing adjustment creates or may create double taxation in cross-border situations.
TTP helps clients assess the available options, prepare the technical position and manage the process from a tax and transfer pricing perspective.
TTP's transfer pricing work is informed by practical experience in tax inspections, risk assessment, Romanian transfer pricing legislation, OECD-related transfer pricing evaluations and MAP and APA evaluation processes. This allows us to approach transfer pricing documentation not only as a compliance exercise, but as a strategic risk management tool.
Schedule a meeting with TTP to discuss documentation, benchmarking, audit support, APA, MAP or broader tax strategy implications.
