Alexandru Nanu, Senior Tax Manager at Crowe Romania, stated that multinationals are requesting ANAF to develop a guide for the analysis of intragroup services, based on OECD principles, to ensure a uniform application at the national level. This guide would reduce differences in interpretation between territorial structures and provide predictability for taxpayers.
Nanu emphasized that the success of the program will be evaluated based on future interactions with tax inspectors and the quality of inspection reports. He also mentioned that 35 tax inspectors participated in training sessions dedicated to the analysis of intragroup services, indicating a desire to strengthen expertise in this complex area.
ANAF has analyzed aspects such as the delineation of transactions and the assessment of the benefits obtained by taxpayers, but the lack of a public guide has led to inconsistencies in inspection practices. Promoting a unified approach in the field of transfer pricing is essential to avoid past confusions and controversies.
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