SUMMARY
Transfer pricing represent the prices for goods and services transfer between affiliates. In order to reduce incomes deficit coming from taxes, fiscal authorities search for more incomes, so they are looking more attentively to transfer pricing. Unfortunately, several international disputes arise between fiscal authorities because of increasing divergent national rules. If the authorities do not manage to reach an agreement, they may settle unilaterally the tax base in their own country. As a consequence, a multinational entity shall face the burden of a double taxation. Fiscal authorities began to investigate aggressively transfer pricing determination policies of multinational companies and every time they are striving to make sure that profits are allotted accordingly to each affiliated unit so as to avoid tax reduction by reducing the tax base. That is why, multinationals should implement efficient instruments for risks identification and measurement and they should always be aware of the latest technical and procedural means for solving issues concerning transfer pricing. Romania is not a member of Organization for Economical Cooperation and Development, and this make not possible for taxpayers to claim the Romanian courts, but also fiscal, the official interpretation of double taxation conventions. In Romania, along with the consolidation of fiscal legislation in the field, focused attention has been given to transfer pricing, the means to justify them and their impact on corporate tax.