Romania has deposited its instrument of ratification for the STTR Multilateral Instrument, enabling implementation of the Pillar Two Subject to Tax Rule through existing bilateral tax treaties.
Romania has deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) on 2 October 2026, according to an OECD update.
Romania signed the STTR MLI on 19 September 2024.
The convention provides a framework for implementing the Subject to Tax Rule (STTR) through existing bilateral tax treaties.
In September 2023, the OECD/G20 Inclusive Framework on BEPS concluded negotiations on the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI).
The instrument provides a streamlined mechanism for jurisdictions to incorporate the STTR into their existing bilateral tax treaties without requiring separate bilateral negotiations. The STTR is a treaty-based component of Pillar Two of the OECD/G20 Two-Pillar Solution, which aims to address international tax challenges arising from the digitalisation of the economy and ensure that multinational enterprises pay a minimum level of tax on income earned across jurisdictions.
Specifically, the STTR allows developing Inclusive Framework members to impose additional tax on certain intra-group payments where the recipient is subject to a nominal corporate income tax rate below the minimum threshold. The STTR MLI is open for signature, and interested jurisdictions may contact the OECD Secretariat to participate.
The STTR enters into force for Romania on 1 January 2027.
Earlier, Romania ratified the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI), strengthening its participation in international tax cooperation. The ratification was formalised through Law No. 60, published in the Official Gazette on 30 April 2026.
