The Ordinance updates Law No. 431/2023 to implement the Pillar 2 global minimum tax under EU Directive 2022/2523.
Romania has published Ordinance No. 21 of 28 August 2025 in the Official Gazette on 29 August 2025.
Government Ordinance No. 21/2025 modifies and supplements Law No. 431 of 29 December 2023, which establishes the implementation of the Pillar 2 global minimum tax in accordance with Council Directive (EU) 2022/2523, dated 14 December 2022.
The changes aim to align Romania’s framework with the OECD Model Rules and Directive 2022/2523, providing clearer guidance and transitional protections. Updates include refined definitions and eligibility criteria for transferable tax credits, revised rules for pension service entities, and recalculated formulas for excess profits and effective tax rates.
The ordinance also introduces flexibility in currency and deferred tax treatment, simplifies administrative procedures, and permits optional carryforward of negative top-up tax values.
Additionally, it allows a single Romanian entity to file and pay the national additional tax for the entire group, subject to the required notifications.
Earlier, Romania’s government published Law No. 431/2023 in the Official Gazette on 5 January 2024.
