By Law 52, published on 28 August 2012 in the Official Gazette of the same date, the National Assembly adopted a legislative amendment to the Tax Code to introduce modifications to the transfer pricing rules. The Law is retroactively effective from 1 January 2012.
The main changes are as follows:
| - | transactions between two related entities are subject to the transfer pricing rules, irrespective of whether the taxpayer is a resident of a country which has si… |