On 19 December 2023, the Romanian Chamber of Deputies (lower house of parliament) approved the law to implement the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022.
In addition to the Pillar 2 global minimum tax, this law also includes the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure a minimum corporate tax of 15% for large multinational (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years. The rules apply to all domestic and international groups with a parent company or subsidiary in an EU member state. The bill also proposes implementing a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups.
The IIR and QDMTT apply for financial periods beginning on or after 31 December 2023, while the UTPR generally applies for financial periods beginning on or after 31 December 2024.
Previously, on 5 December 2023, the law was passed by the Senate (upper house).
