Finance News by Forvis Mazars September 2026

Tue | 06.10.2026

Accounting/audit/tax

New transfer pricing rules: large taxpayers will be required to submit transfer pricing documentation to ANAF annually

ANAF Order No. 828/2026 introduces significant changes to the transfer pricing rules, ranging from revised materiality thresholds and a new requirement for large taxpayers to submit their transfer pricing documentation annually, to additional requirements for functional analyses and benchmarking studies.

The new rules apply to transactions carried out from 2026 onwards.

Liviu Gheorghiu, Tax Partner, Forvis Mazars in Romania: “For large taxpayers, the key change is that transfer pricing documentation will effectively become part of the annual tax compliance calendar. If the transfer pricing file is not submitted by the deadline, it will have to be provided, in the event of a tax audit, within a maximum of five business days from the date of the authorities’ request, which means that the documentation must be made available within a very short timeframe. For medium-sized and small taxpayers, transfer pricing documentation will continue to be submitted at ANAF’s request as part of a tax audit, with a deadline of between 30 and 60 days. Against this backdrop, and given the greater level of detail required under the new rules, preparing the documentation well in advance and embedding the process into internal reporting procedures will become increasingly important”.

Parent-Subsidiary Directive reform under the Tax Omnibus: expanding access to cross-border dividend relief

As part of the European Commission’s Tax Omnibus proposal, amendments to the Parent-Subsidiary Directive (PSD) are being considered, with the aim of making cross-border profit distributions within the EU simpler and more efficient.

For multinational groups, the proposed changes could mean broader access to withholding tax relief, easier dividend repatriation and reduced administrative burdens.

In a recent article, Forvis Mazars’ tax experts explored the key proposed changes to the PSD and what they could mean for businesses operating across the EU.

When is the management of loans subject to VAT?

In Case T-184/25, the EU Court held that loan administration services provided by the original lender following the assignment of the receivables constitute taxable services and do not qualify for any of the exemptions provided for in Article 135(1)(b) to (d) of the VAT Directive.

European banks show credit risk stability amid persistent uncertainty

European banks are showing resilience in their credit risk profiles, but this stability comes as uncertainty persists.

In Romania, the picture is similarly resilient. Forvis Mazars’ analysis of nine of the country’s largest banks shows that the deterioration in credit quality anticipated in 2022 has not materialised to the extent initially expected. The median ECL-to-gross exposure ratio declined from 4.6% in 2022 to approximately 3.5% in 2025, while Stage 2 exposures decreased from 17% to around 13%.

“The focus is now shifting from how Romanian banks absorbed the shocks of recent years to how they navigate the next phase of the economic cycle. Fiscal adjustment and subdued growth could put renewed pressure on borrowers, making disciplined credit risk management increasingly challenging”, mentioned Răzvan Butucaru, Partner, Financial Services & Advisory Leader, Forvis Mazars in Romania.

Tax Omnibus Reform of the Interest & Royalties Directive

On 24 June 2026, the European Commission unveiled the Tax Omnibus package, introducing a significant reform of the Interest & Royalties Directive (IRD) aimed at simplifying cross-border financing and intellectual property transactions within the EU.

Key proposed changes include the removal of ownership thresholds and holding period requirements, an extended list of eligible companies, a shift from prior approvals to taxpayer self-assessment and new safeguards against double non-taxation.

Employee transfer risks in M&A transactions: which employment-related costs could the new employer inherit?

In M&A, employee transfers can bring more than people. They can also bring inherited employment risks and unexpected costs. From reporting errors and inaccurate employee data to contractual non-compliance and pay inequities, buyers may assume obligations that existed before the transaction.

Forvis Mazars’ analysis highlights six key employment-related risk areas to consider during due diligence and integration and explains why the first 100 days following a transaction are critical for addressing them.

“Based on our experience with integration projects, most challenges related to employee transfers arise during the implementation phase. Within a relatively short timeframe, large volumes of data, employment contracts, payroll elements and benefits must be aligned, often across different systems and processes. In this context, even seemingly minor discrepancies can multiply when they affect dozens or hundreds of employees. This is why, for HR and payroll teams, transfer preparation, data validation and close coordination among the functions involved are essential to reducing operational risks during the integration stage”, said Anca Lamba, Senior Manager, Outsourcing - HR & Payroll, Forvis Mazars in Romania.

Global private equity survey: share your market insights

Forvis Mazars invites you to participate in its global private equity survey and contribute to the Global Private Equity Market Outlook 2027.

Your input will help capture the priorities, opportunities and challenges facing private equity professionals today, while ensuring that the Romanian market perspective is reflected in the findings of the Forvis Mazars global study.

Complete the survey here.

This article is provided by our Finance Partner, Forvis Mazars Romania.

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