Romania

DAC9 

Through Government Ordinance No. 1/2026, Romania transposed Directive (EU) 2025/872 (DAC9), which amends Directive 2011/16/EU and extends the automatic exchange of tax information between European Union (EU) Member States regarding the Pillar Two top-up tax.

Pillar Two Directive

Directive (EU) 2022/2523 (‘Pillar Two Directive‘) was transposed in the Romanian legislation through Law no. 431/2023, which introduced into the Romanian legislation a complex system of rules for an effective minimum taxation of 15% for multinational enterprise (MNE) groups and large-scale domestic groups with annual consolidated revenues of at least 750 million euros (EUR) in at least two of the four previous financial years. It was published in the Official Gazette no. 8 dated 5 January 2024 and is applicable to financial years starting as of 31 December 2023.

In August 2025, the Romanian government adopted a Government Ordinance amending the implementation law for Pillar Two. Key changes include the obligation for entities subject to these rules to calculate and disclose deferred tax for Pillar Two purposes in their individual financial statements, based on Romanian accounting standards, or alternatively, to opt for applying International Financial Reporting Standards (IFRS) as the basis of accounting (i.e. until this change, only listed companies and financial institutions applied IFRS in Romania). The new requirements take effect from 2025 and aim to improve transparency and consistency in Pillar Two reporting, although detailed application norms are expected.

Value-added tax (VAT)

Change in the standard VAT rate

Effective 1 August 2025, the standard VAT rate increased from 19% to 21%. Most goods and services across the economy became subject to the 21% VAT rate.

Reform of reduced VAT rates

Beginning on 1 August 2025, the previous reduced rates of 5% and 9% are abolished, replaced by a single reduced rate of 11%. This unified reduced rate applies to a limited array of products and services, including human-use medicines, water supply and sewage, food and beverages for human or animal consumption, fertilisers, and pesticides, as well as physical and digital publications, such as books and newspapers.

Many items, however, transition out of the reduced VAT category and become subject to the new 21% standard rate. These include residential immovable properties and certain leisure activities.

Expansion of the small business VAT exemption regime

From 1 September 2025, Romania updated the special VAT exemption regime for small enterprises by increasing the eligibility threshold from 300,000 to 395,000 Romanian leu (RON). This change was introduced through Government Emergency Ordinance (GEO) No. 22/2025.

EU cross‑border VAT exemption for small enterprises

Romania further expanded the flexibility of the small enterprise exemption regime by allowing Romanian taxable persons to apply the small business exemption in other EU Member States, provided that their EU‑wide turnover does not exceed EUR 100,000 and they stay within each Member State’s local thresholds (as well as vice versa).

Updated place‑of‑supply rules for virtual events

Romania updated the VAT place‑of‑supply rules for cultural, educational, and entertainment events that occur in a virtual format. Under the new provisions, business-to-consumer (B2C) services related to virtual events are taxed where the beneficiary is established, creating a clear distinction from physical events and ensuring a fair and consistent treatment within the increasingly digitalised EU services landscape.

Temporary suspension of obligations and sanctions under RO e‑TVA

Throughout 2025, taxpayers benefited from temporary relief for non-compliance with the RO e‑TVA system.

New procedure for obtaining the VAT deferment certificate

The new procedure for obtaining the VAT deferment certificate prescribes the online submission of the necessary file in a centralised customs system.

RO e-Factura

For business-to-government (B2G) supplies (public institutions), e‑invoicing via RO e‑Factura has been mandatory since 2022, requiring businesses to issue structured XML invoices through the national platform.

Electronic invoicing is mandatory in Romania for business-to-business (B2B) transactions between Romanian taxable persons. From 1 July 2024, only invoices sent through RO e‑Factura are recognised as valid invoices for B2B taxable operations. Receiving or booking invoices outside the system is subject to penalties equal to the 15% of the value of the invoice.

From 1 January 2025, Romania expanded the system to include B2C transactions. These should be submitted in the RO e-Factura portal only for reporting purposes. In other words, even though consumers do not retrieve invoices from the system (unlike B2B recipients), but still via traditional means (i.e. PDF, physical format), suppliers must still submit their invoices through RO e‑Factura.

Foreign businesses registered for VAT in Romania are also required to submit e‑invoices for taxable supplies within Romania while still being shared with the recipient using traditional methods.

Originally, invoices had to be transmitted within five working / calendar days (as the case), but amendments effective January 2026 standardised the deadline to five working days across both B2B and B2C transactions.

Certain transactions remain out of scope, such as: 

• Exports. 

• Intra‑Community supplies of goods. 

• Certain simplified invoices that meet specific conditions.

RO e-Transport

RO e-Transport obligations have been initially implemented as of 1 July 2022 and are mandatory for certain categories classified by the authorities as high fiscal risk goods (e.g. fruits and vegetables, alcoholic/non-alcoholic beverages) that are transported on Romanian territory.

Moreover, as of 15 December 2023, RO e-Transport obligations were extended also to international road transport.

Thus, the identification of transports and the generation of the unique UIT codes in the RO e-Transport system is mandatory both for road transports on the national territory of goods with high fiscal risk and for international road transports of goods.

The obligation to report in the RO e-Transport system the data related to the international transport of goods and to obtain the UIT codes is with the following users:

• The consignee listed in the import customs declaration or the sender listed in the export customs declaration for goods that are the subject of the import or export operations, as the cases may be.
• The beneficiary in Romania in cases of intra-Community purchases of goods.
• The supplier in Romania for the intra-Community supplies of goods.
• The depositary in cases of goods that are subject to transit intra-Community transactions, both for goods unloaded on Romanian territory for storage purposes or for the arrangement of a new shipment from one or more consignments of goods, as well as for goods loaded after storage or after the arrangement of a new transport on the national territory for one or more batches of goods.

The road transport operator is required to equip the transport vehicle with telecommunication terminal devices. The driver of the means of transport is required to switch on the positioning device before starting a transport on the national territory and to keep it in operation until it arrives at the declared place of delivery on the national territory or after leaving the national territory. Failure to comply with these rules lead to application of sanctions as of 1 January 2026.

Sanctions for non-compliance with the high fiscal risk goods apply as of 1 January 2023, while the sanctions for the new measures introduced with respect to international road transport apply as of 1 July 2024.

Minimum turnover tax (IMCA)

Law no. 296/2023 introduced the IMCA.

Taxpayers (other than credit institutions and oil and gas companies) that registered a turnover of over EUR 50 million in the previous year and for which the corporate income tax (CIT) is lower than the IMCA will be required to pay CIT at the level of the IMCA. The IMCA is calculated as 0.5% applied on the difference between total revenues and certain deductible elements, such as non-taxable income, value of fixed assets in progress, and accounting depreciation related to new assets. In the case of a tax group, the IMCA is calculated by the responsible legal entity by summing all the group members’ turnovers.

As an exception, companies that have activities in the oil and gas sectors and that registered in the previous year a turnover of more than EUR 50 million will owe, in addition to the CIT, a specific turnover tax.

Credit institutions (i.e. Romanian legal entities and Romanian branches of credit institutions – foreign legal entities) are liable for a newly-introduced turnover tax in addition to the CIT.

Economic operators that exclusively conduct activities of distribution/supply/transport of electricity and natural gas that are regulated/licensed by the National Energy Regulatory Authority are exempt from the application of the IMCA.

IMCA will be eliminated starting with fiscal year 2027 (or the modified fiscal year beginning in 2027). Additionally, the specific turnover tax for companies operating in the oil and natural gas sectors will also be eliminated from fiscal year 2027.

RO e-Sigiliu  

A new national system, RO e-Sigiliu, was introduced based on the use of electronic devices and an IT application that allows the relevant authorities (such as the National Fiscal Administration Agency and the Romanian Customs Authority) to determine the potential points of diversion for the road transport of goods regardless of whether they are in transit or have as their final destination an economic operator on the national territory. 

Measures to combat tax evasion

Law no. 126/2024 introduces greater penalties for acts that constitute tax evasion offences resulting in damages representing VAT owed to the state budget, and it criminalises new acts of tax evasion for situations in which taxpayers do not use national IT systems such as RO e-Transport, RO e-Invoice, e-fiscal registers, the electronic seal of goods, and SAF-T.

Special cases of non-punishment have been introduced for cases in which the damage caused by tax evasion does not exceed the RON equivalent of EUR 1 million.

The act of not withholding certain tax obligations at source has been criminalised and prison sentences introduced.

No additional payment obligations are due as of the date of approval of the restructuring plan for the budget obligations that form the object of the restructuring, with the exception of excise duties.

Dividend tax

For dividends distributed as of 1 January 2026, the dividend tax rate has been increased from 10% to 16%.

Withholding tax (WHT) on dividends obtained by non-residents

For dividends distributed as of 1 January 2026 by a Romanian resident to a non-resident, the dividend tax rate has been increased from 10% to 16%.