On 28 January 2020, the Government of Romania has published Ordinance no. 5 of 28 January 2020 in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements. The Directive includes measures to require the reporting of cross-border tax planning arrangements and the automatic and mandatory exchange of information reported with other EU Member States.

The Romanian legislation will enter into force on 1 July 2020 and will be effective from 1 July 2020. Failing to report or delayed reporting will result in penalties of RON 20,000 to RON 100,000 and failure by an intermediary to notify another intermediary or relevant taxpayer of a reporting obligation will result in penalties of RON 5,000 to RON 30,000.