#7 Romania’s Tax on Affiliates: A New Era for Intra-Group Services and Royalties (See Description!)

Important update: this is no longer in effect!The Romanian tax authorities announced that they will revoke the tax on affiliates. This is due to a discussion they had with the OECD commission, in which concerns were brought forward regarding the fact that the application of this new piece of legislation is contrary to the OECD principles and standards--------------------------------------------------------------------------------------------------------------------Romania’s transfer pricing landscape is shifting fast, and a new “tax on affiliates” is changing how multinationals think about intragroup charges, deductibility, and audit exposure. With a 1% deductibility cap in play, tax teams need to understand what’s covered, what’s uncertain, and what actions to take now to stay in control.In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by:🔹 Mihai Lupu - Partner at TPS Romania 🔹 Rudolf Sinx - Managing Director at Quantera GlobalTogether, they break down the new Romanian measure in practical terms, discuss how it compares internationally, and explore mitigation routes like APAs, documentation strategy, and potential operating model adjustments.Key topics discussed:00:00: Introduction & Guest Backgrounds00:49: Romania’s “Tax on Affiliates” and the 1% deductibility cap02:57: Scope, thresholds and key changes05:47: Deductibility rules and TP11:12: International context and why a 1% cap is unusually rigid15:59: What MNEs should do now20:45: APAs and mitigations29:48: Summary & Closing RemarksThis episode is packed with real-world insight and practical steps to help you anticipate enforcement, reduce surprises, and make defensible decisions under evolving rules.🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/