Tax Lawyer Romania — Tax Advisory for Foreign Companies

Profit tax or micro-enterprise tax

From 2026 the micro-enterprise regime applies a single 1% rate on revenue to companies whose annual revenue does not exceed €100,000 and that meet the conditions on employees, ownership and activities. Companies outside the regime pay 16% profit tax.

Because the thresholds and conditions changed in 2025 and 2026, a structure that was optimal two years ago may no longer qualify. We check eligibility against the current consolidated text before advising.

Dividends and treaty relief

Dividends distributed by Romanian companies from 1 January 2026 are subject to 16% withholding tax. A non-resident shareholder may obtain a lower treaty rate, or an exemption under the EU Parent-Subsidiary Directive, if it provides a valid certificate of tax residence and meets the holding conditions.

VAT registration and cross-border trade

Romanian VAT is 21% (standard) and 11% (reduced) since 1 August 2025. Companies trading within the EU need a VAT code for intra-community transactions, and non-resident companies may need to register or appoint a fiscal representative depending on their activity in Romania.

Challenging an ANAF tax decision

After an inspection, ANAF issues a tax decision (decizie de impunere). It can be challenged by an administrative appeal (contestație) filed within 45 days of communication, under the Fiscal Procedure Code. If the appeal is rejected, the decision can then be challenged in the administrative courts.

Deadlines are strict and the appeal must address each contested amount with arguments and evidence, so documents should be reviewed as soon as the inspection report is received.

Transfer pricing for group companies

Transactions between related parties must follow the arm's length principle. Depending on size and transaction values, Romanian companies may be required to prepare a transfer pricing file on request or annually, and missing documentation is a frequent issue in tax inspections of foreign-owned companies.