Transfer Pricing

The world is changing … and so does international tax law. Each tax jurisdiction is keen to preserve or increase its taxable base but exactly how much of the pie is it entitled to get?

Biriş Goran began developing its transfer pricing practice more than two years ago and it already successfully assisted companies in diverse sectors such as energy, real estate, finance, and telecommunications – all in the preparation of transfer pricing files.

The transfer pricing department of Biriș Goran pays particular attention to the changes in the international and local legislation such as the anti-BEPS measures, Anti Tax Avoidance Directive, OECD recommendations and the introduction of Romanian Ministry of Finance Order 442/2016 on transfer pricing, as well as to the increased focus of the tax authorities on profit transfers.  In this regard, Biriș Goran provides comprehensive assistance on all fiscal aspects of intra-group transactions.

Given the business environment in Romania, having qualified transfer pricing advice is particularly important to the successful operation of a group of companies.  Our transfer pricing practice managed by Alina Andrei in collaboration with the tax and legal departments of Biriș Goran is geared towards assisting clients not only in the preparation of the transfer pricing file, but also in the mitigation of double taxation and in the overall sustainability of the transfer pricing methodology put in place. In her career, Alina Andrei has handled more than 80 complex transfer pricing files of intra-group dealings since the enactment of Order 222 / 2008.  The most important projects she was involved in include major companies such as local entities of HP group, Romcarbon, Greentech and Gealan Romania.

Our practice also includes assisting our clients during tax inspections and providing comprehensive assistance in resolving any tax disputes with the authorities at all levels.

Recent major projects include:

Assistance to Transbitum Constanța, an important local bitumen producer, in the preparation of the transfer pricing file and representation in front of the tax authorities;

Assistance to Tinmar Ind, important energy trader, in the preparation of the transfer pricing documentation file;

Assistance to LeasePlan, the largest player in the operational leasing and fleet management sector, in the preparation of the transfer pricing file and identification of potential risks in relation to its intra-group transactions;

Assistance to Veranda Obor, one of the leading and newest shopping center in Bucharest, in analyzing the market prices for its future intra-group transactions;

Assistance to Net Connect, an important telecommunications services provider, in the preparation and update of the transfer pricing documentation file;

Assistance to EP Global Energy, an important producer of renewable energy, in the preparation and update of the transfer pricing documentation file;

Assistance to Meat Pack Industries, an important horsemeat processor, part of the Belgian group - Chevideco.

Ongoing transfer pricing assistance to Gealan Romania, a leading producer of PVC profiles with production, administration and logistics functions in Romania;

Ongoing transfer pricing assistance to Romastru Trading, one of the largest traders of the local pharmaceutical industry;

Ongoing transfer pricing assistance to the local entities within the HP group.  Alina successfully assisted them during their transfer pricing audits.

Preparation of the transfer pricing file of Ana Imep, an important company within Ana Holding.  The preparation of the TP file was a particular requirement of the Japanese investor Nidec, before the acquisition of Ana Imep.

Preparation of the initial transfer pricing files of Romcarbon, Greentech and Greenfiber, important players in the recycling industry.  Alina successfully assisted them during their transfer pricing audits.

On-going transfer pricing assistance to Anvis Rom, Satu Mare part of Sumitomo Riko Group, involved in the production of spare parts for the automotive industry.

Preparation of the transfer pricing file for the local branch of Società Italiana per  Condotte D’Acqua Spa Roma, involved in the construction of highways, roads, railways, hydraulic and irrigation projects.

Preparation of the transfer pricing files of Minmetal and North Star Shipping before they were taken over by the American Group – ADM, an important global agricultural processor.