Alina Andrei, Cabot Transfer Pricing

Could you briefly introduce yourself and tell us about your role at Cabot? What does your work in transfer pricing involve on a daily basis??

Above all else, I am an entrepreneur — one in tax and transfer pricing. I started as a freelance consultant more than 10 years ago, and today I am heading a team of 10 people at Cabot.

On a daily basis, after I leave my 3-year-old at kindergarten , I focus on expanding the business, while still being involved in operations. I mainly work on strategic projects, such as large clients, complex transfer pricing documentations, Advanced Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs) and, more recently, AI-related initiatives in our field.

I work primarily with international groups operating in Romania, including Swiss-owned companies.

Transfer pricing is often perceived as complex and highly technical. What attracted you to the area of finance?

I was drawn into rather going directly to it and I must say I did not initially plan a career in tax. 

During my third year at the Faculty of Business Administration (Fabiz) in ASE , our accounting professor recommended a few top students to start as beginners within the Ministry of Finance, in the Large Taxpayers Division. That experience exposed me early on to how tax works in practice.

Later, I joined the Transfer Pricing Department of KPMG in Romania, and this is where I truly discovered the field - KPMG gave me the knowledge and the structure. After several years, I decided to start my own transfer pricing company.

At different moments in my career, I did question whether a completely different role would be more fulfilling. However, I strongly believe that there is great value in building deep expertise over time, especially in a field that requires both technical knowledge and judgement. I also realised that meaningful contribution can take many forms, including through education and mentoring initiatives.

What are the most common challenges companies face when it comes to transfer pricing documentation and compliance?

One of the more recent transfer pricing challenges relates to the limitation on the deductibility of certain expenses (management, R&D, consultancy services received from foreign related parties) for companies with a turnover below EUR 50 million.

There is, however, an important exception: this limitation does not apply to companies that have an Advanced Pricing Agreement in place for such services.

Our recommendation is that companies affected by these rules perform a cost–benefit analysis, comparing the impact of the deductibility limitation with the alternatives available — standard transfer pricing documentation or an APA — in order to identify the most suitable solution for their specific situation.

How does your work in transfer pricing support strategic decision-making for international companies?

As transfer pricing becomes more strategic, many companies start considering an APA rather than relying solely on standard documentation.

Together with my team, we support clients in making informed decisions by analysing their intercompany transactions, risk profile and overall risk tolerance, while also taking into account the expectations of both local tax authorities and group headquarters.

What skills or qualities do you believe are essential to succeed in a field like transfer pricing?

Transfer pricing is a field that requires a high tolerance for uncertainty. Revenues are often annual — the transfer pricing file is prepared once a year — while costs and responsibilities are continuous.

As a result, planning and budgeting are essential. 

At the same time, it is important to understand clients’ businesses well enough to anticipate their questions and information needs, and to request the necessary data in a way that does not create unnecessary administrative burden for them.  Currently, we are working on a AI driven software solution that would minimise the input and the time spent by our clients in preparing TP related data and questionnaires.

Outside working hours, how do you usually disconnect from numbers, regulations, and deadlines?

My 3 year old daughter makes me disconnect the moment she sees me.  She simply wants to play and spend time together, so once I get home, my attention is entirely hers.

What is something about you that might surprise people who know you only in a professional context?

I am quite an exploratory spirit and I enjoy travelling to remote places. A few years ago, for example, I visited Ushuaia, the southernmost city in Argentina and the starting point for expeditions to Antarctica.

I also enjoy hiking and skiing, and I am very much looking forward to travelling more with my daughter in the future and create memories with her.

What does being part of the Switzerland–Romania business community mean to you, personally and professionally?

For me, this community represents an opportunity for dialogue and learning, as well as a platform for knowledge sharing and practical support — both for Swiss companies navigating the Romanian business and tax environment and for Romanian companies looking to launch projects in the Swiss market.

I was impressed by Adriana’s openness — we actually met during a flight between Timișoara and Bucharest, where she managed to convince me, in just ten minutes, to become a member of the Chamber. That interaction made me curious to further explore how I can contribute, particularly by sharing practical insights related to tax and transfer pricing for companies operating between Switzerland and Romania.

Beyond the professional aspect, I am also interested in learning more about Swiss business culture and people — and, of course, I already appreciate Switzerland for its landscape and ski resorts.