Romania has ratified the Multilateral Convention to Implement the Pillar Two Subject to Tax Rule (STTR MLI), enabling the country to apply minimum tax rates to certain cross-border income under its bilateral tax treaties. The ratification, formalised through Law No. 60 published on 30 April 2026, follows Romania's signing of the convention in September 2024.
Romania has officially ratified the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI), marking a significant step in international tax cooperation. The ratification was formalised through Law No. 60, published in the Official Gazette on 30 April 2026.
The STTR MLI was originally adopted in Paris on 15 September 2023 and opened for signature on 2 October 2023. Romania signed the convention on 19 September 2024, demonstrating its commitment to the global tax framework. The convention enables jurisdictions to impose tax on certain income categories that are subject to nominal tax rates below the established STTR threshold in bilateral tax treaties.
Upon depositing the instrument of ratification, Romania has made several important notifications. The country will identify its covered tax agreements subject to the convention, listing the relevant treaties, contracting jurisdictions, and any amending instruments with their signature and entry dates.
Romania has also confirmed its application of taxes calculated on the basis other than net income, as permitted under the convention’s provisions. Additionally, the country has elected to incorporate the definition of “Recognised Pension Fund” and provisions concerning interruption into its covered tax agreements.
Romania has chosen a specific approach for the convention’s entry into force, opting for an effective date 30 days after the depositary receives the final notification from all contracting jurisdictions confirming completion of their domestic procedures. This approach replaces the standard timeline references outlined in the convention’s Article 12.
The ratification aligns with constitutional requirements under Articles 75 and 76 of the Romanian Constitution. It reflects the country’s participation in the global effort to address tax base erosion and implement minimum taxation standards.
