Romania plans major ANAF reform and merger with Customs Authority

The Mureșan government has proposed a strategic reform of the National Agency for Fiscal Administration (ANAF) as part of its governing program. A central component of this plan is the reunification of ANAF with the Romanian Customs Authority to create a single fiscal and control body. The reform aims to combat large-scale tax evasion through risk-based controls and specialized teams focusing on complex areas such as transfer pricing, intra-group transactions, and digital business models.

To improve efficiency, the government intends to implement a performance-based bonus-malus remuneration system for ANAF leadership and operational structures by December 31, 2026. This mechanism, aligned with PNRR commitments, will link bonuses to the exceeding of collection targets and apply penalties for underperformance.

Additionally, ANAF is updating regulations regarding transfer pricing documentation. Starting January 1, 2026, major taxpayers will be required to submit annual transfer pricing files through the Virtual Private Space (SPV) within 30 working days of their annual profit tax return deadline. These changes include expanded requirements for functional analysis and more detailed comparability studies, particularly for transactions involving entities registered outside of Romania.