Romania
Corporate taxes and other direct taxes
CIT is 16%. To calculate the taxable profit, the accounting profit is adjusted upwards (with non-deductible expenses) or downwards (with non-taxable revenues). An additional deduction of no more than 50% can be applied for certain R&D expenses.
Starting with 01/01/2024, entities with a turnover exceeding €50 million are required to pay a minimum 1% tax applied to adjusted turnover if the CIT computed under general rules is lower than the 1% turnover tax. Operators in the oil and gas sectors will have to pay a 0.5% tax applied to adjusted turnover, while credit institutions will pay a 2% turnover tax for the period of 2024-2025 and 1% starting with 01/01/2026.
Capital gains arising from the sale of the participations held in any state that Romania has concluded a DTT with are non-taxable.
Tax consolidation is applicable in the field of CIT at the level of two or more legal entities. Once tax consolidation has been opted for, it must be applied for 5 years.
The tax incentive can be applied, through which CIT payers can benefit, under certain conditions, from annual CIT discounts (2% up to 15%), which is applicable until FY 2025.
Tax losses can be carried forward for a period of 5 years and offset with taxable profits up to 70%.
Treaty network consisting of around 88 DTTs.
The WHT on Dividends is 8%.
The WHT for Interest and Royalties is 16%.
Capital gains from the sale of shares are tax exempt (certain conditions apply). In all other relations for WHT, the general tax rate and DTTs are applicable.
In 2024 MLI provisions will affect the covered agreements in Romania.
From 2024, shareholders with more than 25% shares in a micro-company cannot have additional shareholdings in other companies that apply the same regime.
2 tax rates are applicable for the micro tax regime.
The 3% tax is reintroduced, however turnover has to be between EUR 60k and EUR 500k, or the company has to have certain NACE codes. The 1% tax is still applicable for turnover of less than EUR 60k.
Legal entities in certain domains are not eligible to apply the micro tax regime (insurance, gambling).
The incentive implemented to stimulate the capitalization of CIT payers is also applicable for microenterprise taxpayers for the tax due in the fourth quarter of the fiscal year.
| Transfer pricing in Romania |
| Arm's length principle |
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Since 2003 (Law 227/2015)
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| Documentation liability |
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Since 2003 (Order 222/2008, Order 442/2016)
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| APA |
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Since 2007 (Order 3735/2015)
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| Country-by-Country liability |
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Non-Public CbCR and Public CbCR (early adoption with FY 2023) are applicable in Romania
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| Master file-local file (OECD BEPS 13) applicable |
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Only Local File rules are applicable.
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| Penalty |
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| - lack of documentation |
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For large and medium tax payers – approx. EUR 2,500-2,900
Other taxpayers – EUR 410-720
Adjustment of tax base plus late payment interest and penalties.
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| - tax shortage |
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regular tax regime
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| Related parties |
minimum of 25%
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Direct or indirect control
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| Safe harbors |
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OECD's simplified approach on low value adding services is not applicable in Romania.
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Level of attention paid by Tax Authority:
VAT and other indirect taxes
General rate is 19%. Reduced rates are 9% (e.g. medicines, food, agricultural products, hotel, restaurant services, certain residential sales and photovoltaic systems etc.) and 5% (e.g. books).
VAT-exempt activities include medical services, financial and banking services, insurance and reinsurance, sale and rental of real estate, sale of medical prostheses and orthopedic products, certain types of educational and training activities, and other activities of public interest.
E-invoicing systems are mandatory as of 01/01/2024 for taxpayers who perform B2B transactions considered to take place in RO. Starting with 01/07/2024 for the purposes of deduction the original invoice is considered to be the xml file received in the e-invoice system, together with electronic signature attached by Ministry of Finance.
The e-transport system for the real time tracking of goods is mandatory as of 15/12/2023 for all taxpayers who arrange the transport of goods for all kind of international carriages and as of 01/07/2022 for those classified as a tax risk within Romania (e.g. fruit, vegetables, alcoholic drinks, clothing, footwear, and certain minerals and metals).
As of 01/01/2024 non-alcoholic beverages with a sugar content exceeding 5 gram/liter are subject of excise liability.
SAF-T is already implemented for large and medium taxpayers and as of 01/01/2025 will be mandatory for all taxpayers.
| VAT options in Romania |
Applicable / limits |
| Distance selling |
The OSS system is applicable. |
| Call-off stock |
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| VAT group registration |
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| Cash accounting - yearly amount in EUR (approx.)* |
EUR 900,000/year
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| Import VAT deferment |
Certificate of payment deferral / AEO / simplified customs procedure / products subject to VAT r/c
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| Local reverse charge |
For sale of: certain types of waste, certain types of cereal, wood, greenhouse gas emission certificates, electricity, natural gas, green certificates, land and buildings, laptops, and mobile phones
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| Option for taxation |
| - letting of real estate |
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| - supply of used real estate |
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| VAT registration threshold* |
approx. EUR 60,000
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Personal income tax / Social security system
A 10% flat tax rate is applicable to revenues obtained from dependent activities (e.g., employment or activities assimilated to employment) or independent activities (freelancers).
SSC are the following: Social Security Contribution/Pension (25% – employee part), Health Insurance Contribution (10% – employee part) and Work Insurance Contribution (2.25% – employer part).
Income received from dependent activities is subject to SSC at the employee (35%) and the employer level (2.25%). As of 2024, the annual base for calculating SSC for some categories of income is amended.
As regards the SSC/Pension Contribution due for income received from independent income and IP rights, this is due in case the income is at least 12 minimum gross salary (e.g RON 3,300 for 2024, thus RON 36,000 per annum). The 25% is applied to the following computation base regardless of the level of revenues obtained:
- base of 12 minimum gross salaries in case the level of the obtained revenue is between 12 and 24 minimum gross salaries;
- base of 24 minimum gross salary in case the level of the obtained revenue exceeds 24 minimum gross salaries.
The Health Insurance Contribution (HIC) is applied to the annual net income obtained by the freelancer and the taxable base cannot be higher than 60 minimum gross salary (capped at this value). For other types of income (rental income, dividend, capital gain, etc. - except salary income), the HIC is due as follows:
- base of 6 minimum gross salaries in case the level of the obtained revenue is between 6 and 12 minimum gross salaries;
- base of 12 minimum gross salaries in case the level of the obtained revenue is between 12 and 24 minimum gross salaries;
- base of 24 minimum gross salary in case the level of the obtained revenue exceeds 24 minimum gross salaries.
Wage related taxes
in Romania |
Minimum wage |
Average wage in private sector |
| Exchange rate RON/ EUR |
in EUR |
in RON |
in EUR |
in RON |
| 4,94 |
667 |
3,300* |
1,530 |
7,5697 |
| Total wage cost |
682 |
102.25% |
1,564 |
102.25% |
| Employer contributions |
15 |
2.25% |
34 |
2.25% |
| Gross salary |
667 |
100.00% |
1,530 |
100.00% |
| Employees` contributions |
233 |
35.00% |
535 |
35.00% |
| Personal Deduction ** |
133 |
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- |
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| Personal income tax*** |
30 |
10.00% |
99 |
10.00% |
| Net salary |
404 |
60.50% |
895 |
58.50% |
* The minimum monthly gross wage guaranteed in payment, without including bonuses or other additions, is RON 3,300 for FY 2024, for a normal working schedule. In the construction sector, the minimum monthly gross wage for the period January 1, 2024 – December 31, 2024 is RON 4,582 per month (without including other bonuses and additional payments).
** 1 family member is assumed
*** Personal income tax base is: gross salary - employee's contribution - personal deduction