Romania

The standard CIT rate is 16% for Romanian companies, foreign companies operating through a permanent establishment (PE) in Romania and foreign companies that are tax resident in Romania due to place of effective management. Resident companies are taxed on their worldwide income unless a double tax treaty (DTT) stipulates otherwise. 

The CIT due for nightclubs and gambling operations is either 5% of the revenue obtained from such activities or 16% of the taxable profit, whichever is higher.

Minimum turnover tax (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 CIT is lower than the IMCA are required to pay CIT at the level of the IMCA. 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 owe, in addition to the CIT, a specific turnover tax (ICAS).

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.

Specific turnover tax (ICAS) for oil & gas companies

Government Ordinance No. 3/2025 (GEO No. 3/2025) clarified the scope of application of (ICAS) for Romanian and foreign legal entities operating in the oil and natural gas industries, starting with the fiscal year 2025 or the modified fiscal year starting in 2025.

Specifically, GEO No. 3/2025 clarifies the application of ICAS for the Romanian legal entities but also to non-resident legal entities performing activities in the oil & gas sector, which in an individual manner or through an association deliver goods/provides services on the Romanian. 

ICAS should be declared and paid for quarters I - IV, by the 25th of the month following the respective quarter.

In order to avoid the risk of non-payment of ICAS, non-resident legal entities carrying out activities in the oil & gas sector, which have not registered a permanent establishment in Romania, are required to provide a guarantee letter issued by a credit institution or to make a deposit to a unit of the State Treasury in favor of the central fiscal body. The amount of the guarantee is 1 million EUR, equivalent in RON, established at the exchange rate communicated by the National Bank of Romania on the date of provision of the guarantee.

Micro-company tax regime

A Romanian legal entity can opt for the application of micro-company revenue tax in lieu of the standard CIT if it cumulatively meets the following conditions as of 31 December of the previous year:

• The revenues derived did not exceed the RON equivalent of EUR 250,000. Before 2025, this threshold was EUR 500,000 and it will be further reduced to EUR 100,000 starting 1 January 2026.
• The share capital is owned by persons other than the state and administrative-territorial units.
• It is not under dissolution, followed by liquidation.
• Has at least one employee, except tax consultancy.
• Has associates/shareholders that hold, directly or indirectly, more than 25% of the value/number of participation titles or voting rights and is the only legal entity established by the associates/shareholders to apply the micro-company provisions.
• Has submitted the annual financial statements on time if it has this obligation according to the law.

The micro-company regime cannot be applied by Romanian legal entities conducting activities in banking; insurance and reinsurance of the capital market, including intermediation activities in those fields; gambling; or exploration, development, or exploitation of oil and natural gas deposits.

The tax rate on micro-company revenues is:

• 1% for micro-companies with revenues that do not exceed EUR 60,000 and do not carry out activities related to the following NACE (“CAEN”) codes: 5821 - Editing of computer games, 5829 - Editing of other software, 6201 - Custom (client-oriented) software development activities, 6209 - Other information technology service activities, 5510 - Hotels and similar accommodation, 5520 - Holiday and other short-stay accommodation, 5530 - Camping grounds, recreational vehicle parks and trailer parks, 5590 – Other accommodation, 5610 - Restaurants, 5621 - Event catering activities, 5629 - Other food service activities n.e.c., 5630 - Bars and beverage serving activities, 6910 - Legal activities - only for legal entities that are not fiscally transparent, established by lawyers according to the law, 8621 - General medical practice activities, 8622 -Specialist medical practice activities, 8623 - Dental practice activities, 8690 - Other human health activities, 6210 - Custom (client-oriented) software development activities, 6290 - Other information technology service activities, 5611 - Restaurants, 5612 - Food service activities of mobile food facilities, 5622 - Other food service activities n.e.c.     .
• 3% for micro-companies with revenues of more than EUR 60,000 or that carry out  primary or secondarycertain specific activities corresponding to the above-mentioned NACE codes.

If a micro-company derives revenues of more than EUR 250,000 then it owes CIT as of the quarter in which they exceeded those limits.

The calculation and payment of tax for micro-companies shall be performed quarterly, by the 25th day (inclusive) of the month following the quarter for which the tax is calculated. 

The dividend income received from a subsidiary located in another member state of the European Union can be excluded when calculating the micro-company tax, to the extent that both the micro-company and the subsidiary meet the EU Parent-Subsidiary Directive conditions. Dividend income received from a Romanian legal entity can be excluded without any conditions.

The dividend income received from a subsidiary located in another member state of the European Union can be deducted when calculating the micro-company tax, to the extent that both the micro-company and the subsidiary meet the EU Parent-Subsidiary Directive conditions.

Local income taxes

There are no county or local taxes on corporate income.

Construction Tax

The construction tax has been reinstated as of 1 January 2025, as follow:

• It is calculated by applying a 1% rate to the value of the constructions existing in the the taxpayer’s assets as at 31 December of the previous year, other than the ones for which building tax is due. The value of buildings in industrial, scientific and technological parks that do not benefit from building tax exemption, is also subject to construction tax provisions.
• The constructions are those stipulated in Group 1 of the Catalog regarding the classification and standard useful lives of fixed assets.
• For constructions of the public/private domain of the state or administrative-territorial units, the tax is owed by taxpayers which have them under administration / concession / use for free / rent.
• Taxpayers are obligated to calculate and declare the construction tax by May 25th of the year for which the tax is owed.
• Construction tax should be paid in two equal installments by June 30th and October 31st.