Romania taxes residents on worldwide income and non-residents on Romania-source income only. Romania operates a self-assessment system for corporate tax, with the National Agency for Fiscal Administration (ANAF) conducting post-filing review.
The Romanian tax year is the calendar year. For calendar-year filers, the annual corporate income tax return is due 25 March of the following year; quarterly returns are due by the 25th of the month following each quarter (except the fourth).
Romania's headline corporate income tax (CIT) rate is 16%.
The headline personal income tax (PIT) rate is 10%.
The standard VAT/GST (or equivalent consumption tax) rate is 21%.
An individual is a Romanian tax resident if any one of the following applies: domicile in Romania, center of vital interests in Romania, or presence in Romania for more than 183 days in any 12-month period ending in the relevant calendar year. Residency via vital interests takes effect from the date of formal declaration; residency via the 183-day test is deemed to run from the first day of arrival. Anyone crossing the 183-day threshold must submit a residency questionnaire to ANAF within 30 days. Residents are taxed on worldwide income (flat 10% rate); non-residents only on Romania-source income.
A non-Romanian entity has a Romania permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Romania on the entity's behalf, following the OECD Model Treaty definition as applied under Romanian domestic law and any applicable tax treaty.
Under Romania's CFC rules (implementing EU ATAD), a Romanian tax resident must include in its taxable base the non-distributed income of a qualifying CFC (entity or permanent establishment), proportional to its participation.
Romania has no formal debt-to-equity thin capitalization ratio. Instead, an ATAD-based interest limitation rule caps deductible excess borrowing costs at 30% of tax-adjusted EBITDA for costs exceeding EUR 1 million (loss-making taxpayers may fully deduct excess borrowing costs up to this EUR 1 million threshold regardless). Disallowed costs carry forward indefinitely, including proportionally to a successor entity following a merger or division. The rule does not apply to standalone entities outside a consolidated group, or to loans financing long-term public infrastructure projects; it is also irrelevant for taxpayers under Romania's microenterprise tax regime, which does not generally allow deductions.
Romania does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics. Romania has implemented ATAD2-aligned anti-hybrid rules and a GAAR disallowing non-genuine arrangements carried out for the main purpose of obtaining a tax advantage.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Romania provides a participation exemption for qualifying dividends and capital gains: a Romanian company holding at least 10% of a Romanian, EU, or DTT-treaty-country subsidiary's share capital for a continuous minimum 1-year period is exempt from Romanian corporate tax on dividends received and on capital gains from disposing of that shareholding (dividends between two Romanian companies are exempt with no minimum holding requirement at all). Foreign-source income from a CFC is included in a Romanian tax resident's taxable base proportionally to their participation, with relief mechanisms to avoid double-counting on subsequent actual distribution.
Romania has a real foreign tax credit regime available to both individuals and companies for foreign tax paid on foreign-source income also taxed in Romania, capped at the Romanian tax otherwise due on that income.
Romania maintains an extensive network of more than 90 tax treaties.