Romania's tax authority has introduced standardised forms and filing procedures for multinational and large domestic corporate groups to comply with the country's new global minimum tax regime, requiring detailed reporting on corporate structures, tax calculations, and jurisdictional compliance within strict deadlines.
Romania published Order No. 218, issued by the National Agency for Fiscal Administration (ANAF) on 16 February 2026, in its Official Gazette on 24 February 2026. The order sets out the official templates and procedural rules for two key forms connected to the implementation of the global minimum tax (GIR) in Romania.
This order is a direct result of Law no. 431/2023, which ensures a minimum level of taxation for multinational and large national enterprise groups.
Order 218/2026 pertains to new reporting requirements for large multinational and domestic groups. It introduces specialised tax forms, specifically the Top-up Tax Information Return and a corresponding Notification of the filing obligation, to ensure a minimum global level of taxation.
The regulations establish strict submission deadlines, generally set at 15 months after the fiscal year ends, though an extension to 18 months is granted for the initial implementation period.
Comprehensive instructions are provided for digital filing through the e-governance portal, requiring valid electronic signatures and specific software provided by the tax authority.
Additionally, the order details the extensive data points required, including corporate structure changes, effective tax rate calculations, and various jurisdictional safe harbours. These measures aim to align national fiscal procedures with international standards for taxing significant corporate entities.
Below is an elaboration on the key aspects of this regulation:
The two primary forms
The order introduces two specific documents that affected entities must manage:
- The informative declaration regarding additional tax (Annex 1): A comprehensive document used to report detailed data about the group’s structure, accounting standards, and tax calculations.
- The notification regarding the obligation to file the informative declaration (Annex 3): A preliminary document used by taxpayers to notify fiscal authorities of their requirement to submit the main declaration.
Filing deadlines and payment
The regulation sets specific timeframes for compliance, linking the filing of the forms with the payment of the tax itself:
- Standard deadline: Both forms must be submitted within 15 months of the last day of the reporting fiscal year. This date also serves as the deadline for the payment of the additional tax.
- First-year exception: For the initial year of application, a grace period is granted, extending the deadline to 18 months from the last day of the reporting fiscal year.
- Alternative fiscal years: These deadlines apply equally to taxpayers who have opted for a fiscal year different from the calendar year.
Comprehensive reporting requirements
The Informative Declaration (Annex 1) is highly detailed, requiring data across several categories:
- Group identification: Includes the name of the ultimate parent entity (UPE), its fiscal identification number (NIF), and the specific accounting standards (e.g., IFRS) and reporting currency used for consolidated financial statements.
- Corporate structure: Entities must report changes in the group structure, identifying constitutive entities, joint ventures, and “excluded entities” (such as governmental entities or non-profits).
- Safe harbours and exclusions: The form provides sections for opting into transitional or permanent safe harbour regimes, simplified calculations for non-significant entities, and de minimis exclusions.
- Technical tax calculations: It includes specific fields for calculating the Effective Tax Rate (ETR), adjusted covered taxes, and adjustments for deferred taxes. It specifically addresses rules like the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), and the Qualified Domestic Minimum Top-up Tax (QDMTT).
Technical submission procedures
Formularies must be completed using ANAF’s free assistance program and submitted electronically through the e-guvernare portal as PDF files with XML attachments. Submissions require a qualified digital certificate per Law no. 214/2024. Any corrections must be filed as rectificative forms containing all original information, including unchanged data.
Notification specifics
The notification (Annex 3) permits a designated local entity to file collectively for multiple constitutive entities within the same jurisdiction. It requires detailed contact information and must specify whether the local jurisdiction will receive the main Informative Declaration through international information exchange with the ultimate parent entity’s jurisdiction.
Earlier, Romania’s tax authority (ANAF) opened a public consultation on a draft order issued by its President on 7 November 2025. The draft concerned the approval of the format and content of the forms for the GloBE Information Return (GIR) and the related notification on the obligation to file it.
