In addition, companies should also consider reactive instruments such as the mutual agreement procedure, administrative complaints and even disputes before the Romanian courts. Multinational enterprises (MNEs) are already under extensive transfer pricing (TPs) scrutiny around the world, changes in transfer pricing rules related to BEPS, the rise of the digital economy and the strengthening of information exchange by authorities are leading to growing risks and controversies over transfer pricing. Nevertheless, transfer pricing tax controversies are expected to intensify. It is therefore essential for companies operating in Romania to take steps to avoid transfer pricing controversies while being ready to manage and settle disputes that inevitably arise. In Romania, recent years have seen an increase in the number of tax audits carried out by the National Agency for Tax Administration (NAFA), with a focus on transfer pricing issues, as well as an increase in the number of tax cases triggered by transfer pricing adjustments. An advance pricing agreement (APA) is a procedural agreement between one or more taxable persons and one or more tax authorities, which aims to avoid transfer pricing disputes by defining in advance a number of criteria applicable to certain cross-border transactions controlled within a specified period of time, in order to ensure that they comply with the full-competition principle. . . .