Is the obligation to translate the documents in the file new?

No. The Romanian Fiscal Procedure Code has long required documents submitted to the tax authority in a foreign language to be accompanied by Romanian translations certified by authorized translators. What is new, for large taxpayers, is the annual file submitted on their own initiative through SPV, with a fixed deadline. Translation thus becomes a yearly job with a deadline, not one requested only during a tax audit.

Does the whole file have to be translated?

Romanian is the official language of the tax administration (Fiscal Procedure Code, art. 8). What has to be translated are the foreign-language documents attached to it: usually the group documentation, intra-group contracts, service agreements and comparability studies received from abroad. What goes into the file is decided with your tax adviser; we translate what you send us.

Does the translation have to be certified?

Yes. Documents submitted to the Romanian tax authority in a foreign language are filed with Romanian translations certified by translators authorized by the Ministry of Justice (the Romanian equivalent of a sworn translator); documents filed without such a translation are not taken into account. ANAF Order no. 828/2026 refers to the same rule: foreign-language documents in the file are accompanied by translations "under the conditions of the law".

We are a small or medium taxpayer. Do we need to translate anything now?

Not on your own initiative. Small and medium taxpayers prepare and present the file only at the request of the tax authority, during a tax audit, within 30 to 60 working days of the request. The translations are done then, for the documents requested. It helps, however, to have the intra-group contracts and the group glossary ready in advance.

Do you keep the editable format and the Excel tables?

Yes. The order requires annexes available electronically (Word, PDF, Excel) to be submitted in an editable format. We translate in the original files, keep the table structure, formulas and worksheets, and with desktop publishing (DTP) the translated document looks like the original.

Guide · Companies

Translating the transfer pricing file: what is filed, in what form and by when

Q: When is the first annual file due?

The annual obligation applies to transactions with related parties carried out from 2026 onwards, and the order applies to procedures initiated after 1 January 2027. The first annual file, the one for 2026, is therefore submitted in 2027, within 30 working days of the deadline for the annual corporate income tax return. Confirm the exact date with your tax adviser.

Updated: 9 November 2026 · Kalimera, translation agency in Bucharest since 2005 · all guides

In short: from 2027, large taxpayers in Romania prepare the transfer pricing file every year and submit it electronically through the Virtual Private Space (SPV, the online portal of ANAF, the Romanian tax authority), within 30 working days of the deadline for the annual corporate income tax return (ANAF Order no. 828/2026). Foreign-language documents in the file are accompanied by Romanian translations under the conditions of the law, that is, certified by authorized translators. The translation requirement is not new. What is new is the fixed deadline, every year: in multinational groups, where the group documentation, intra-group contracts and comparability analyses are often in English, translation becomes a yearly job to plan together with the file.

1. What changes: the annual file, submitted through SPV

ANAF Order no. 828/2026, published in the Official Gazette no. 543 of 2 July 2026, sets out who prepares the transfer pricing file, when and with what content. For large taxpayers, a category established by order of the ANAF president, the rules are:

the file is prepared annually, for transactions with each related party whose value reaches the materiality thresholds: EUR 100,000 for services, EUR 200,000 for interest-bearing financing, EUR 250,000 for intangible assets and royalties, EUR 350,000 for tangible assets, per transaction, at the National Bank of Romania exchange rate for the last day of the fiscal year;
the deadline for preparing it is the legal deadline for filing the annual corporate income tax return;
the file is submitted electronically through SPV, under the signature of the legal representative or an authorized person, within 30 working days of that deadline;
if it was not submitted through SPV, the tax authority may request it during a tax audit, and it must be made available within 5 working days at most.

The annual obligation applies to transactions carried out from 2026 onwards, and the order applies to procedures initiated after 1 January 2027. The first annual file, the one for 2026, is therefore submitted in 2027. Check the thresholds and your company's category with your tax adviser; this guide is about translation.

2. Small and medium taxpayers: the file only during a tax audit

Small and medium taxpayers prepare and present the file only at the request of the tax authority, during a tax audit, for transactions reaching their own thresholds: EUR 50,000 for services, EUR 100,000 for financing, EUR 150,000 for intangible assets and royalties, EUR 200,000 for tangible assets. The deadline for presenting it is 30 to 60 working days from the request and can be extended once, by up to 30 working days.

For translation, this means the job comes suddenly, with a short deadline, in the middle of a tax audit. Documents you can prepare in advance, such as intra-group contracts and service agreements, are worth translating ahead of time.

3. Which documents in the file are usually in a foreign language

Romanian is the official language of the tax administration, but in multinational groups many parts of the file come from abroad, most often in English:

the group information, the section prepared along the lines of the Master File documentation in the OECD Transfer Pricing Guidelines, usually drafted by the parent company;
the contractual documents underlying the transactions: intra-group contracts, service agreements, loan and licence agreements;
the comparability study and the supporting documents on the data used, when the analysis is done at group level;
where applicable, the independent auditor's report on the profitability indicator of the tested party, when the tested party is not the Romanian company.

Under the order, missing contractual documents, comparability analysis or financial information means the file is presented incomplete. That is why translating these parts is not a formality: they are part of the file.

4. What form of translation the law requires

The order says that foreign-language documents in the file are accompanied by Romanian translations "under the conditions of the law". Those conditions are in the Fiscal Procedure Code (art. 8): supporting documents, certificates and other documents submitted to the tax authority in a foreign language must be accompanied by Romanian translations certified by translators authorized by the Ministry of Justice. Documents filed without such a translation are not taken into account. In Romania, "authorized translator" is the official term for what other countries call a sworn translator; what it means and how to check it is explained in the guide authorized translator in Romania.

Notarization and the apostille are not required by these texts for the file. If another recipient, for example an authority abroad, asks for something else, ask first.

5. Editable format, tables and figures

Editable format. Annexes that are also available electronically (Word, PDF, Excel) are submitted to the tax authority in an editable format, and the comparability study is also presented in Excel, with the search strategy, the accepted and rejected comparables and the calculation of the range. The translation is therefore done in the original file, not in a flat PDF, with worksheets, formulas and table structure kept.
Separators. In Romanian, a comma separates decimals and a point separates thousands; in English it is the other way round. In the tables of the file, where every row is a value, a figure transcribed wrongly changes the result.
Consistency with the financial statements. The list of related-party transactions must be reconciled with the accounting records and the financial statements. The names of the items in the translation must be the same as in the translated financial statements, not another variant. How terminology stays the same year to year is explained in the guide translating financial statements.
Transfer pricing terminology. The arm's length principle, functional analysis, tested party, interquartile range, central tendency of the market: these terms have established Romanian equivalents and must be used consistently throughout the file.

6. How to plan a translation with a fixed deadline

Start with what is stable. Intra-group contracts and service agreements rarely change: translated once, they are reused year after year, with the addenda updated.
Ask for the group documentation early. The group information is prepared in another country and often arrives late; its translation can start as soon as the final version exists, before the rest of the file is ready.
Set a glossary. The names of related companies, transactions and financial items are fixed once and kept the same in the file, in the translations and in the following years.
Leave room for checking. The 30 working days run from the deadline for the corporate income tax return, so the file and the translations are usually worked on in the same period as the annual corporate income tax return. A translation deadline agreed in advance avoids the rush at the end.

How we work at Kalimera

Financial and tax documents are at the core of our work. Transfer pricing files are translated by authorized translators who know financial and tax terminology, including that of the OECD Guidelines. We use the translations from previous years and the group glossary, so names stay the same year after year. We work in the original Word and Excel files and keep tables through desktop publishing (DTP), so the annexes remain editable. We work under strict confidentiality procedures and sign a non-disclosure agreement on request. For large files we assign a dedicated team, with deadlines agreed in advance. Details on the page financial translations.

Sources

Order of the ANAF President no. 828/2026 on the value of transactions, deadlines for preparation, content and conditions for requesting the transfer pricing file and the procedure for adjusting/estimating transfer prices (Official Gazette no. 543 of 2 July 2026), art. 2, 4, 5, 7, 15 and annexes no. 2 and 3;
Law no. 207/2015 on the Fiscal Procedure Code, art. 8 ("Official language in tax administration") (consulted in November 2026).