Moldova vs Romania: a Transfer Pricing Perspective

Abstract

The importance of the transfer pricing topic has grown increasingly in the past years, due to globalization process and the expansion of multinational business structures. As cross-border intra-group transactions intensify, national tax systems face growing challenges in ensuring compliance with the arm’s length principle and preventing base erosion. This article undertakes a comparative analysis of the transfer pricing frameworks in the Republic of Moldova and Romania, highlighting both similarities and structural differences in their legal and administrative approaches. While scientific literature extensively addresses transfer pricing in developed economies and EU Member States, comparative studies involving emerging or transition economies remain relatively rare. By examining the Moldovan and Romanian experiences, the article contributes to the academic debate on regulatory convergence, enforcement capacity, and the practical effectiveness of transfer pricing rules in differing institutional contexts. Thus, the paper itself focuses on qualitative research, by comparing the legal framework governing transfer pricing in both countries. The results have shown that although the legislation of the Republic of Moldova and Romania is comparable in terms of principles and objectives, it is not fully equivalent from a functional point of view. Comparability is more theoretical and normative than practical, requiring taxpayers and multinational groups to adopt differentiated approaches to compliance and tax risk management, tailored to the specificities of each jurisdiction. UDC: 338.516+347.73(478+498); JEL: H25, H32, K34