Business Taxation — Romania

Applied to taxable profits of Romanian legal entities and permanent establishments. Quarterly advance payments required. Annual reconciliation via corporate tax return. Losses can be carried forward up to 7 years with 70% annual offset limit.

Simplified regime for companies with turnover under €100,000 (reduced from €250,000 in 2025). Single 1% rate (3% rate eliminated). Must maintain minimum number of employees. No sector restrictions from 2026. Much lower administrative burden. Significantly reduced eligibility threshold.

For large companies with turnover over €50 million. Reduced from 1% to 0.5% in 2026. Applied to gross turnover. Minimum tax obligation even if losses. Valid through December 31, 2026 (through end of modified fiscal year ending in 2027).

New restriction from 2026: expenses for IP rights, management, and consultancy paid to non-resident affiliated entities deductible only up to 1% of total expenses. Applies to companies under €50M turnover. Exceptions: advance pricing agreements. Significant impact on multinational structures.

Additional tax on turnover for banks: 4% rate (increased from 2% July 2025). Banks with market share under 0.2% pay 2%. Applied in addition to 16% corporate income tax. Significant burden on banking sector. Rate continues through 2026.

Romania enforces OECD transfer pricing guidelines. Arm's length principle applies to related party transactions. Documentation requirements for transactions over certain thresholds. Advance pricing agreements available. Penalties for non-compliance significant.

Increased from 19% to 21% from August 1, 2025. Single reduced rate: 11% (replaces previous 5% and 9% rates). Applies to food, medicine, books, cultural services. Significant increase impacts business costs. Registration threshold: RON 300,000 (approximately €60,000).

Employers must file consolidated payroll declaration (Form D112) by 25th of following month. Submit through ANAF online portal. Includes income tax, CAS, CASS, CAM. Late filing penalties: 0.01% per day. Electronic Labor Registry (REGES-Online) mandatory from 2026.

Corporate income tax return due within 150 days of fiscal year end. For calendar year: by May 25. Financial statements required. Audited statements for larger companies. Electronic filing mandatory. Penalties for late filing and non-compliance.