On 6 December 2007, the decree of the Council of Ministers on transfer pricing has been adopted (Official Gazette of 6 December 2007, No. 26722). The decree, which applies to both resident and non-resident individuals and corporations, clarifies the arm's length principle, transfer pricing methods, advance pricing agreements and transfer pricing documentation. The decree shall be retroactively applied from 1 January 2007.
Procedural rules on transfer pricing published
…