Romania Tax Guide 2026

Corporate income tax

Art. 13–42 Fiscal Code · Standard rate, returns, deductibility, depreciation, interest, minimum tax, Pillar Two

Taxpayers

Romanian legal entities (except micro-enterprises and tax-transparent entities), foreign legal entities with their place of effective management in Romania, permanent establishments of non-residents, and foreign legal entities deriving income from the transfer of real property located in Romania.

Tax year and filing deadlines

Carry-forward of tax losses

• Losses arising after 1 January 2024 — carry-forward for 5 years, limited to 70% of the taxable profit of the period.
• Losses arising before 2024 — carry-forward for 7 years, subject to the same 70% cap.
• No carry-back is allowed. Changes in shareholding do not affect carry-forward.

Deductibility of expenses — selection

Tax depreciation

• Methods: straight-line, declining-balance, accelerated (up to 50% in the first year).
• Super-accelerated depreciation 2026 — available for new assets in sub-groups 2.1 (technological equipment) and 2.4 (animals and plantations) commissioned in 2026.
• Minimum fixed-asset value: RON 5,000.
• Vehicles (≤ 9 seats, not used exclusively for business): tax depreciation capped at RON 1,500/month.

Limitation of interest expenses

Excess borrowing costs are fully deductible up to the following thresholds:

• EUR 500,000 for transactions with related parties (excluding financing of assets under construction);
• EUR 1,000,000 aggregate (related and unrelated parties).

Above the threshold, deductibility is limited to 30% of the tax EBITDA base. The non-deductible excess may be carried forward indefinitely.

Minimum turnover tax (IMCA)

Pillar Two — global minimum tax

Applicable to groups (domestic and multinational) with consolidated turnover ≥ EUR 750 million in at least 2 of the past 4 years. Minimum effective rate: 15% per jurisdiction.

• QDMTT and IIR — applicable in Romania from 1 January 2024.
• UTPR — applicable from 1 January 2025.
• Filing deadline (GIR): 15 months from the end of the financial year (18 months in the first year).

Micro-enterprise income tax

Art. 47–57 Fiscal Code · Single 1% rate, EUR 100,000 threshold, conditions, exit from the regime

Eligibility threshold

Income ≤ EUR 100,000 as at 31 December of the previous year (RON equivalent at the closing exchange rate). The threshold is tested by cumulating the taxpayer's revenue with that of related enterprises (Law 346/2004 — over 25% direct or indirect control), under Art. 47 para. (1¹) Fiscal Code.

Cumulative conditions

• At least 1 full-time employee (or its equivalent through aggregated part-time contracts; or a management agreement with remuneration ≥ the minimum wage);
• Shareholders / partners holding directly or indirectly over 25%, being the sole entity designated by them to apply the regime;
• Share capital held by parties other than the State / local authorities;
• Annual financial statements filed on time;
• Not in dissolution followed by liquidation.

Excluded activities

Banking, insurance and reinsurance services (except for secondary intermediaries ≤ 15% of revenue), capital-market activities, gambling, exploration / development / exploitation of oil and natural gas deposits.

Exit from the regime

Filing and payment

Quarterly, D100 — by the 25th of the month following the quarter.

Personal income tax

Art. 58–134 Fiscal Code · Standard rate 10%, dividends 16%, capital gains, gambling, the single tax return

Rates by type of income

Personal deduction (salaries)

Applicable to employees with gross income ≤ minimum wage + RON 2,000 (RON 6,050 in the first half of 2026, with a minimum wage of RON 4,050). The deduction ranges between 0.05% and 45% of the minimum wage, depending on the number of dependents and the income level.

Filing and payment

• Salaries, dividends, interest, IP rights, rental income from up to 7 rooms — withheld at source.
• Independent activities, long-term rentals, capital gains, other sources — Single Tax Return (D212): filing and payment by 25 May of the following year.

Mandatory social contributions

Art. 135–224 Fiscal Code · Thresholds expressed in gross minimum wages · Employees, self-employed, passive income

Employees

Independent activities (self-employed / PFA, PFI, liberal professions)

CAS 25% — Social insurance contribution

• Net income < 12 minimum wages (RON 48,600): not owed (optional).
• Net income between 12 and 24 minimum wages (RON 48,600–97,200): base = 12 min. wages → CAS = RON 12,150.
• Net income > 24 minimum wages (above RON 97,200): base = 24 min. wages → CAS = RON 24,300.
• Pensioners do not owe CAS.

CASS 10% — Health insurance contribution

• Computed on net income actually earned, capped at 72 minimum wages (RON 291,600 → maximum CASS RON 29,160).
• Net income < 6 minimum wages (RON 24,300): minimum contribution of RON 2,430, with exemptions for: employees whose CASS through the employment contract is ≥ RON 2,430, students under 26, persons with grade I/II disability, pensioners.
• Loss or zero income: CASS exemption.

CASS on passive income (dividends, rent, interest, crypto, securities)

Value added tax (VAT)

Art. 265–334 Fiscal Code · Law 141/2025 · New rates from 1 August 2025, registration threshold RON 395,000

Transactions at the 11% reduced rate

• Food (exceptions: alcohol, NC 2202 beverages, foods with sugar ≥ 10g/100g except infant milk, food supplements);
• Human / veterinary medicines (excluding food supplements);
• Water for irrigation, water supply and sewerage;
• Fertilisers, pesticides, seeds and specific agricultural services;
• Books, textbooks, newspapers, magazines — both print and electronic;
• Access to castles, museums, memorial houses, historical monuments, zoos and botanical gardens;
• Firewood and wood waste for heating;
• Thermal energy during the cold season — for the population, schools, hospitals, NGOs, religious denominations, social services;
• Supply of dwellings within the social policy framework.

Transitional 9% rate for housing

VAT registration

Exemption threshold: RON 395,000 annual turnover (Art. 310 Fiscal Code). Registration is mandatory starting with the transaction that exceeds the threshold.

Tax period and filing

Digital obligations 2026

• RO e-Invoice — mandatory B2B and B2C for all transactions between Romanian parties (including to consumers, from 2025).
• e-VAT — pre-filled return sent by ANAF; the taxpayer confirms or corrects any differences.
• RO e-Transport — for goods of high fiscal risk and international transports.
• SAF-T (D406) — extended to all taxpayers in 2026.

Cash-accounting VAT scheme

Optional for taxpayers below the prescribed threshold; chargeability of the tax shifts to the moment the consideration for the supply / service is collected.

Local taxes and duties

Art. 453–500 Fiscal Code · Buildings, land, vehicles, special duties

Building tax

Land tax

Varies based on the locality's rank, zone and use category (built-up / non-built-up, arable, forest, etc.).

Vehicle tax

Computed per cubic centimetre of engine displacement, in RON / 200 cm³, with surcharges for high-emission cars.

Deadlines

• 31 March — first instalment; discount of up to 10% for full payment.
• 30 September — second instalment.

Special duties

Set by decisions of the Local Councils: sanitation, advertising, issuance of certificates and authorisations.

Special tax on high-value real estate and movable assets

Title X¹ · Art. 500¹–500³ Fiscal Code · Luxury dwellings, luxury vehicles

Luxury residential buildings (individuals)

• Applicable if the taxable value of the building (Art. 457) exceeds RON 2,500,000 (≈ EUR 500,000).
• Rate: 0.9% on the difference between the taxable value and the RON 2,500,000 threshold.
• Notice from the local tax authority by 30 May.
• Filing and payment: by 30 September.

Luxury vehicles (individuals and legal entities)

• Applicable to vehicles with an individual acquisition value above RON 375,000 (≈ EUR 75,000).
• Rate: 0.9% on the difference between the acquisition value and the RON 375,000 threshold.
• Owed for 5 years from the date the vehicle is delivered.
• Filing and payment: by 31 December.

Excise duties

Title VIII Fiscal Code · Harmonised products (alcohol, tobacco, energy) and non-harmonised products

Indicative 2026 levels — harmonised products

Non-harmonised excise duties

Products containing tobacco (heat-not-burn, electronic devices) and nicotine liquids for e-cigarettes — specific rates; check Annex 2 of the Fiscal Code.

Payment of excise duties

Monthly, by the 25th of the month following that in which chargeability arose.

Customs duties

Regulation (EU) 952/2013 · Law 86/2006 · TARIC

Legal framework

Romania applies the common customs policy of the European Union. Goods circulate freely within the EU without customs duties. Customs duties apply only to imports from outside the EU, according to the Common Customs Tariff (TARIC).

Charges on import

Customs value

Determined under Art. 69–76 of the EU Customs Code — preferably the transaction value (price actually paid + adjustments).

Origin

• Non-preferential origin — for the application of general trade policy measures.
• Preferential origin — reduced duties or exemptions under EU free trade agreements (CETA, EU-UK TCA, EU-Japan, EU-South Korea, EU-Vietnam, EU-Mercosur etc.).

Customs procedures

Release for free circulation · Transit (T1, T2, NCTS) · Customs warehousing · Inward / outward processing · Temporary admission · Export.

Authorised Economic Operator (AEO)

• AEOC — customs simplifications;
• AEOS — security and safety;
• AEOF — combined.

Benefits: reduced controls, prioritisation, mutual recognition with third countries.

Import VAT reverse charge

VAT-registered taxpayers may benefit from deferral of import VAT, the tax being booked through the reverse-charge mechanism (Art. 326 Fiscal Code), thereby avoiding the cash-flow impact.

Withholding tax — non-residents

Art. 221–234 Fiscal Code · Domestic rates, EU directives, double tax treaties

Rates for non-residents

Applicable EU directives

• Parent-Subsidiary Directive — dividend exemption if a holding of ≥ 10% is maintained for at least 1 year.
• Interest and Royalties Directive — exemption for payments between EU affiliated companies (holding ≥ 25%, minimum 2 years).

Double tax treaties

Fiscal procedure — deadlines, interest, penalties

Law 207/2015 — Fiscal Procedure Code

General limitation period

• 5 years for tax obligations (Art. 110).
• 10 years for claims arising from a criminal offence.

Interest and penalties

Payment rescheduling

• Simplified — up to 12 months, no guarantees required, accessible online via SPV.
• Standard — up to 60 months, with real guarantees and / or bank guarantee letters.

Tax audit

• Maximum duration: 180 days for large taxpayers, 90 days for medium, 45 days for the rest.
• Notification through the Tax Audit Notice: minimum 30 days (15 for small / medium taxpayers).

Administrative appeal

Filing deadline: 45 days from communication of the administrative act. Resolution within a maximum of 6 months (extendable to 12 months for complex cases).

Virtual Private Space (SPV)

Exclusively electronic communication for legal entities and self-employed (PFA / PFI). Individuals — optional, with the possibility to request paper communication.

2026 tax calendar — key deadlines

Main filing and payment obligations throughout the year

2026 tax news — overview

Main changes from 2025 — Law 141/2025, GEO 156/2024, GEO 89/2025