The transfer pricing documentation file must be submitted by March 25th, 2017, which is the deadline for filing the corporate tax return, or by the deadline set for companies that apply any tax year other than the calendar year.
The file has to be prepared and presented according to ANAF Order No. 442/2016 on the amount of transactions, submission deadlines for the transfer pricing documentation file, the content and conditions of requesting the preparation of a transfer pricing documentation file, and the transfer pricing adjustment/estimation procedure.
It is important to note that the interpretation of this Order by tax authorities is that, in case of a tax audit, if the file is requested for the past three years, companies must update the file according to the Order for the entire audited period, which is basically a retroactive application of the document. With audited companies, the deadline for meeting legal requirements is usually 30 to 60 days.